1. Introduction

This document (hereinafter – K&AP) constitutes Cryptology Key Labs LTD(hereinafter – KL, or us) police on combatingmoney laundering, terrorism financing, and other illicit activities. Itestablishes standard procedures and controls with regard to the applicableregulation for the purpose of combating any adverse effect of such activitieson the integrity of the digital assets markets.

K&AP applies to all employees, stakeholders,contractors and clients of KL, notwithstanding jurisdiction of origin.

With implementation of thispolicy, we are striving to comply with the applicable AML/KYC laws, regulations and guidelines with following:

• We prevent the     use of KL services for money laundering, terrorism financing, or any other     illicit activities;
• We identify     and mitigate potential risks associated with money laundering, terrorism     financing or any other illicit activities;
• We construct our activities in a such manner, which ensures full     transparency of all of our processes related to provision of our services.

Itis crucial to uphold to our K&AP in all cases in order to ensure andmaintain the integrity of KL operations and reputation on the market.

We have a unit which is incharge of the AML/KYC matters – financial department, whose representative you can reach inorder to ask any question in regard AML/KYC and related issues via this email [emailaddress for support].

2. Standards

2.1. In general

KL, to the fullest extent of our best efforts,assesses the risks of money laundering, terrorism financing and other illicitactivities taking into account risk factors relating to the clients themself, countriesor geographic areas of client’s origin and transactions.

Considering K&AP in place, KL has establishedcertain standards to identify our clients before entering into a businessrelationship.

2.2. Inadmissibility

KL undertakes, considering the ongoingrussian-Ukrainian war, to take every measure necessary to ensure non-provisionof services to the russian and belarusian citizens, residents and legalentities.

With this document KL constitutes the inadmissibilityof the abovementioned persons, their affiliated and related persons (withwhom such persons may have business or other relations, e.g., ownershiprelations).

3. Due diligence

3.1. Client Identification

KL shall collect comprehensive information toaccurately identify and verify the identity of all clients as follows by using [instrument for gathering KYCinformation]:

For individuals,this includes obtaining the following:

·    full legal name (first, second and last name);

·    date of birth;

·    nationality;

·    residential address;

·    government-issued identification document (internal or international);

·    proof of location;

·    basic information on sourceof wealth;

·    other relevant information(may be requested ad hoc).

For legal entities,this includes obtaining the following:

·    legal name;

·    registration number;

·    registered address;

·    corporate documents;

·    beneficial ownership structure;

·    director structure;

·    identification of shareholders, directors (and/or representative);

·    relevant legal opinions relating to the client’s business;

·    other relevant information(may be requested ad hoc).

3.2. Individual risk assessment

The factors taken into account for the individual riskassessment and classification (low/medium/high) of our clients on arisk-sensitive basis are the ones that are as follows:

·     platform/vendor risk;

·     asset/service ortransaction risk;

·     client risk;

·     geographical risk;

bearing in mind the inherent risk nature and businessstandards of the digital assets market.

3.3. Enhanced due diligence

For clients presenting higher risks, KL may conductenhanced due diligence procedures, which includes obtaining additionalinformation, enhanced monitoring, and seeking shareholders’ approval forengaging in any business relationship.

Examples of risk factors that may trigger such enhanceddue diligence may include:

·     jurisdiction oforigin/residence/citizenship;

·     jurisdiction of birth orincorporation;

·     nationality;

·     profession/occupation;

·     substance of economicactivity;

·     appearance on sanctionlists (OFAC, EU Commission, NSDC of Ukraine, and other authorities ofrelevant jurisdictions);

·     PEP-status (politicallyexposed persons) of clients, representatives, beneficial owners and theirfamily members;

·     source of wealth;

·     type of client;

·     type and size of payment,which may be expected;

·     reputation of the clientin relation to the digital assets market.

3.3.1. Source of funds and wealth

KL may request detailed information relating to thesource of funds or wealth of clients, particularly those presenting higherrisk. This may include requesting documentation such as

·     bank statements;

·     trade history;

·     token deployment contracts;

·     token distribution modelsand solutions;

·     business financial records.

If needed, further verification of the legitimacy ofthe client's source of funds or wealth may be undertaken to ensure that he/she isconsistent with his/her declared financial activities and registrations.

3.3.2. Business relationships

For the clients, who conduct business involvingtransactions with high-value assets, complex ownership structures, or involvingjurisdictions known for high levels of financial crime – in-depth backgroundchecks may be conducted on beneficial owners, senior management, and otherassociated parties in order to assess their reputability and potential riskfactors.

Such clients may be requested to provide any and allrelevant information to mitigate risks assessed.

3.4. Ongoing monitoring

KL carries periodic and risk-based reviews in order toensure that client-related documents, data or information are kept up-to-date.

An enhanced ongoing monitoring shall be conducted forthose clients presenting high risk for KL. This includes regular reviews ofclient’s activity, transaction patterns, and any relevant changes in riskfactors assessed.

Any significant changes in the client's profile orbehavior may trigger a reassessment of the client's risk rating, and theapplication of additional due diligence measures if necessary.

4. Monitoring of Transactions

KL implements transaction monitoring systems andprocesses to detect and investigate suspicious activities using [instrument of monitoring of activity].Transaction monitoring could include the following:

·     real-time monitoring oftransactions on subject-matter of unusual patterns, large, complex orinconsistent transactions;

·     retrospective analysis oftransactions in order to identify potentially suspicious activity;

·     regular reviews oftransaction logs and reports.

5. Record Keeping

Records of personal data, obtained for the purposes ofthe prevention of money laundering and terrorism financing or other illicitactivities, are processed and kept in accordance with the requirements of theapplicable law of relevant jurisdiction (when and where applicable – to GDPR),and shall not be further processed in a way that is incompatible with thosepurposes. You may refer to our Privacy Policy (hereinafter – PP),[lprivacy policypage], where we address all the relevant issues and provide contactsfor inquiries on privacy matters.

6. Internal Measures

6.1. Reporting

Suspicious transactions shall be reported incompliance with the respective laws and regulations by means of the responsibleperson. Issues and activity reports are reviewed on a regular basis. Thequality of coverage of the internal control may be reviewed on an ad hoc basis.

6.2. Training

KL conducts regular training and awareness programs toall employees and vendors in order to ensure they understand their AML/KYCobligations, and are skilled enough to identify and report suspiciousactivities effectively.

6. Conclusion

KL is committed to maintaining the highest standardsof integrity in due course of our business. This K&AP reflects ourdedication to preventing illicit activities and protecting the integrity of ouroperations. All employees, stakeholders, vendors and clients are expected toadhere strictly to the provisions of this K&AP.

This K&AP may be reviewed periodically and updatedas necessary to reflect changes in laws, regulations, and industry bestpractices.

7. Our contacts

Send us an email to the following address [support@keylabs.tradewith the subject matter of your concern (any of the aforementioned or else)related to AML/KYC subject-matter, and we shall answer you at our firstconvenience.

Our Service is provided to you by:

Cryptology Key Labs LTD

Registry code: 15893692

Address: 128, City Road, London,

EC1V 2NX, England, United Kingdom

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