AML/KYC Policy

1. The Anti-Money Laundering and Anti-Money Laundering/Know Your Client Policy (the “AML/Policy”) is in place to prevent and reduce potential risks to LaFinteca from any illegal activities.
2. LaFinteca adheres to all international measures against any activity that facilitates money laundering.
3. LaFinteca warns customers about the imminent criminal liability for attempting to use the Service for money laundering, terrorist financing, drug, and human trafficking, preventing the spread of weapons of mass destruction, and corruption. However, the Service is not responsible for any illegal activities of third parties.
4. To prevent the use of the Service for illegal activities, LaFinteca imposes several requirements for all Requests created by Customers:
   • The service strictly prohibits transfer to third parties’ requisites: only one person can be the sender and the recipient of the Application.
   • All the contact details provided by the Customer in the Application must be up-to-date.
   • The Service categorically forbids the Customers to create an Application using proxy servers or through third-party/anonymous IP addresses.
5. An essential measure to prevent unauthorized activity is verifying the Customer’s identity (further referred to as Verification). The Service has a unified Verification procedure for
   this purpose.
6. LaFinteca has the right to require the following data, documents, or information from the Customer to identify the Customer and confirm the sources of funds:
   • Photo of the Customer with a passport/ID card on which the owner’s photo and full name must be clearly legible.
   • A scan or high-quality photograph of the passport (first and second page, as well as the page with the residence registration) or ID card (back and backside, as well as
     the Extract from the State Population Register of the place of residence registration).
   • Confirmation of the source of income (photos, screenshots, bank statements).
   • Video-confirmation: the client has to stand in front of the camera with his passport/ID card so that the photo and name are clearly visible, and say the number of the LaFinteca application created by him, as well as say that the funds sent are his own and he is responsible for them. The video should also mention the source of
     the funds.
7. If unauthorized activity is detected or an official investigation is conducted, the Service may freeze funds temporarily until the verification or investigation is completed.
8. If the Customer makes any changes to the personal data provided to the Service or carries out suspicious activities, LaFinteca has the right to verify the Customer’s identity again.
9. All information received by the Service about the Customer’s identity will be stored and used in accordance with the LaFinteca Service’s Privacy Policy and related regulations.
10. The Service has the right to refuse to provide its services to the Customer after the Customer has confirmed their identity if the Service is used for unlawful purposes.
11. To use payment cards to consume the Service facilities, the Customer must pass the card verification per the LaFinteca rules.
12. The Service may audit the source of the funds to verify the legality of the ways in which the Client receives the funds.
13. The AML compliance has the responsibility of a person authorized by the Service, whose responsibility is to ensure compliance with the Policy.
14. The authorized person has to monitor LaFinteca’s AML compliance activities using the following methods:
    • Collecting user identification information.
    • Establishing and updating internal policies and procedures to complete, review, submit, and retain all reports and records required under applicable laws and regulations.
    • Monitoring transactions and investigating any significant deviations from normal activity.
    • Implementing a records management system to store and retrieve documents, files, forms, and logs.
    • Regularly updating the risk assessment.
    • Providing law enforcement agencies with the information required under applicable laws and regulations.
15. A person authorized by the Service may cooperate with law enforcement authorities to prevent misconduct on the Service by the Customer.
16. LaFinteca performs system functions that are necessary to comply with the Policy, including:
    • Checking Customers daily for the existence of recognized blacklists (e.g., OFAC), aggregating transmissions across multiple data points, placing users on watch lists and denial of services, opening cases for investigation where it will be appropriate, sending internal communications and completing mandatory reports if it is applicable.
    • Administration of the affairs and document management.
17. The Service reviews Customers, including through analysis of transaction behavior, relying on it as a tool for risk assessment and identifying suspicious activities.
18. In line with international requirements, the Service implements risk assessment practices to combat money laundering and anti-money laundering. Thus, the Service ensures that measures to prevent or mitigate money laundering and terrorist financing are commensurate with identified risks.
19. If suspicious activity is detected on the part of the Customer, including for the purpose of money laundering, the Service has the right to:
    • Suspend the User’s operation.
    • Request identification documents from the User.
    • Request any additional information and documents from the User in case of suspicious transactions.
    • Ensure that the suspicious nature of the transactions is reported to the appropriate law enforcement authorities through an authorized AML compliance officer.
20. According to the above information, the Service is not legally liable for the use of its services for money laundering, terrorist financing, or the purchase of illegal goods and
    services. At the same time, the Service takes all available steps to prevent any attempts to use this service for unlawful purposes.
21. According to the clauses of the applicable regulations, the Customer agrees to all the above terms of the Policy and undertakes to comply with them when carrying out the Service.