Verator UAB AML POLICY

AML & KYC POLICY of UAB VERATOR

1. OBJECTIVE OF THE AML POLICY

UAB Verator (“Company”) is under the obligation to apply anti-money laundering (“AML”) requirements in our business. All our staff is committed to pursuing the highest standards of AML/CTF and Know Your Customer (“KYC”) compliance to mitigate the risk of our services being used to facilitate financial crimes.

We have implemented the framework of AML measures and KYC procedures to ensure that all the necessary steps are taken to achieve the full safety of our services. In this AML Policy, we are committed to following the provisions specified in the Lithuanian AML laws, EU and international AML/CTF guidelines.

2. WHAT IS AML POLICY?

This AML Policy is the measures to prevent our services from being used for the purposes of money laundering, terrorist financing or any other criminal activity. KYC procedures are part of the AML Policy. The objective of KYC procedures is to enable businesses to know and understand their Clients better and help them manage their risks. We may update such procedures in the future to assure compliance with the existing laws and best AML practices.

Our AML Policy includes:

•    Identification and verification of the client before entering a financial business relationship – KYC procedures.

•    Establishment and maintenance of the risk-based client due diligence, including enhanced due diligence for those clients presenting higher risks.

•    Transactions monitoring of the client’s financial behaviour based on risk-based analysis.

•  Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities.

•    Periodical AML trainings for our staff.

We implemented the following KYC procedures to comply with AML/CTF standards:

Client's Identity verification:

The Client must deliver trustworthy, independent source documents, data, or information to COMPANY in order for COMPANY to carry out its identity verification process (namely, national ID, international passport, bank statement, utility bill as a proof of address). For these reasons, COMPANY reserves the right to gather Client identity data in accordance with the AML/KYC Policy.

The COMPANY will take measures to ensure that the documents, data, and information provided by the Client are authentic. The COMPANY will use all legal methods to confirm identification information, and it maintains the right to investigate certain Clients who have been determined to be potentially risky or suspicious.

When the Client 's identification information has been changed or their activity seems suspicious (unusual for the Client), COMPANY reserves the right to verify the Client's identity in an on-going basis. Additionally, even in case the Client have previously passed identity verification, COMPANY has the right to request up-to-date documents from him.

After verification the Client's identification, COMPANY can absolve itself of any potential legal responsibility in the event that its Services are used to carry out illegal activity.

Client’s Card verification:

Clients who intend to use their credit or debit cards in connection with the COMPANY's services must successfully complete card verification in accordance with the instructions posted on the COMPANY's website.

Sanctions and PEP lists screening:

COMPANY screens applicants against Sanctions and Politically Exposed Persons (PEPs) lists.

Individuals and legal entities are screened:

·       during the onboarding stage, when the Client submits the application;

·       on each anti-fraud and AML alert manually by the Compliance Officer;

·       monthly by running automatically with a script to re-check all customer databases.

The COMPANY uses the proprietary software and the World-Check One online search tool (provided by Refinitiv) to execute the screening process. WorldCompliance data from LexisNexis is integrated into the software.

In case of any potentially suspicious or unusual transactions or client behaviour, we undertake appropriate measures to address the risks that occurred. All staff handling transactions may ask for additional documents such as proof of source of funds etc. as deemed appropriate.

We keep a well-organized procedure for maintaining all records, including client identification documents and related data. All Client and transactional information are stored confidentially and according to the COMPANY's Privacy Policy and any other related applicable laws.

We are obligated to reject the client’s documents, block or close the account, cancel any payments and terminate the business relationship if we find any suspicious activity, false documents, or non-cooperation by the Client within the Client's KYC and due diligence process.