Anti-Money Laundering Policy

Anti-Money Laundering Policy

Anti-Money Laundering Policy

This Anti-Money Laundering Policy (“Policy”) is a part of our voluntarily applied regime to prevent money laundering, terrorist financing, fraud, or other financial crime. References in these Terms to “we”, “our” or “us”, are to UAB Amonra Limited, and references to “you”, “your” are to the person, including both individuals and entities, accessing or using our software, applications or services.

Upon accessing or using our software, applications or services, you agree to be legally bound by and to comply with this Policy that can be amended from time to time at our sole discretion.

Definitions

The definition “entity” shall include any business, partnership, joint venture, agency, association, firm, corporation, limited liability company or other entity of any kind.

Identification and Verification

1. The performance of identity verification is an essential part of our anti-money laundering regime. We require all our users to pass identity verification upon registration at our software and/or applications and at any moment thereafter.

2. For the purposes of this Policy we may require you to provide us with the following information: first name, last name, address, telephone number, e-mail address, date of birth, taxpayer identification number, a government identification, and, if applicable, information regarding your bank account (such as the name of the bank, the account type, SWIFT code, and account number). Also, we may request from you your driving license or any other national ID, internal or international passport, bank statement, utility bill, tax document and/or other documents that we consider necessary for your identification. We may request from you video identification or your selfie with a specified ID or passport.

3. When you act on behalf of an entity, in addition, we may require such entity to pass entity verification prior it starts using our services and at any moment thereafter. In this case, we may require you to provide us with the following information: business name of the entity, registry code or registration number and the date of registration; ID of the shareholders (same as for the natural person identification), ID of the director(s) and/or members of the management board (same as for the natural person identification), ID’s of the representatives (same as for the natural person identification), proof of the registered office/seat of the entity, ID’s of the beneficial owners (same as for the natural person identification), bank statements, proof of representation and powers; articles of association and/or other information and documents that we consider necessary.

4. The submitted documents (other than driving license, national ID, internal or international passport, articles of association or entity’s by-laws) should be issued no more than three months prior to the date of identification and should list your name and your current address. In providing us with this or any other information that may be required, you confirm that the information is accurate and authentic. You agree to keep us updated if any of the information or document you provide changes.

5. You acknowledge and agree that we may additionally investigate certain of our users who have been determined by us to be of the higher risk or suspicious.

6. You acknowledge and agree that we may use subcontractors for the purpose of your identity verification. In this case processing of the requested information and documents would be governed by such subcontractor’s privacy policy and you would be able to read such privacy policy before you submit any information.

7. You hereby agree to provide us or our subcontractors with the information we or our subcontractors request and you hereby permit us and our subcontractors to keep a record of such information.

8. You authorize us and our subcontractors to make inquiries, whether directly or through third parties, that we and our subcontractors consider necessary to verify your identity, prove your address, prove a source of your funds or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries.

9. We shall have the right to verify your identity, request you to prove your address, request you to prove a source of your funds on an on-going basis, including cases when your identification information has been changed or your activity seemed to be suspicious (unusual for you). We reserve the right to request up-to-date documents from you and/or represented entity, even though you have passed identity verification in the past.

Restricted and High-Risk Regions

We may refuse your use of our software, applications or services if you are:

a. A citizen, a permanent resident or located at any state, country, territory or other jurisdiction that is embargoed by the United Nations or Lithuania;

1. a citizen, a permanent resident or located at any state, country, territory or other jurisdiction where your purchase, ownership and/or use of crypto assets would be illegal or otherwise violate any applicable law;

2. an entity established at or carrying day-to-day management from any state, country, territory or other jurisdiction, specified in subsections (i)-(ii) of this Section;

3. you are restricted or barred from conducting banking or financial transactions, in any jurisdiction or under any applicable laws;

4. you are placed on any list of suspicious persons banned from traveling or conducting business or financial transactions in any jurisdiction;

5. you are a politically exposed person (“PEP”) or a person connected with the PEP;

6. a representative of any of such persons specified in subsections (i)-(vi) of this Section.

b. Also, we may refuse your use of our software, applications or services if you are a citizen, permanent resident or located in the country which based on various criteria selected by our anti-money laundering team as imposing anti-money laundering or counter-terrorist financing high risk (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by authorities) or you are an entity established at or carrying day-to-day management from such country.

Refusal

a. You hereby acknowledge and agree that we shall have the right at any moment to terminate your use of our software, applications or services without the obligation of any refunds to you in the following cases:

1. you provided us with false or incomplete information, you are reluctant to provide complete information or you refused to provide us with any requested information;

2. you are or become a citizen of, a permanent resident of, or your entity’s day- to-day management is transferred to any of country, territory or jurisdiction specified in subsections (i)-(ii) of Section 3(a) or in the Section 3(b);

3. you are or become restricted or barred from conducting banking or financial transactions, in any jurisdiction or under any applicable laws;

4. you are or were placed on any list of suspicious persons banned from travelling or conducting business or financial transactions in any jurisdiction;

5. you are or become a PEP or a person connected with the PEP;

6. you made a deposit or a payment from cryptocurrency wallets or crypto assets wallets placed at common blacklists or having known security discrepancies;

7. we have the suspicion that you are engaged in illegal activity or you using funds that come from illicit sources.

b. We shall have no liability to you for any damage caused by such termination of your use of our software, applications or services.

Monitoring Transactions. Reporting

1. We may monitor and analyze your transactions. We may perform compliance-related tasks, including capturing data, filtering, record-keeping, investigation management and reporting. We may place you on watch and service denial lists, open cases for investigation where needed, send internal communications and fill out statutory reports, if applicable.

2. We may check addresses of your cryptocurrency or crypto assets wallets against common blacklists and known security discrepancies, to ensure that the funds do not come from illicit sources, and there are no signs of money laundering (location, layers, integration), either manually or using a third party service.

3. We shall have the right to report your transactions of suspicious nature to the proper law enforcement, request you to provide any additional information and documents in case of suspicious transactions.

General Terms

1. We may modify this Policy by providing notice of such changes, such as by sending you an email, providing notice through any of our websites, or by updating the “Last Updated” date at the bottom of this Policy.

2. You acknowledge that our decision to take certain actions according to this Policy may be based on confidential criteria that are essential to security protocols or crime investigation. You agree that we are under no obligation to disclose the details of our security procedures to you.