1. Introduction

This Know Your Customer Policy, hereinafter referred to as the AML and KYC Policy, includes provisions designed to prevent and mitigate Nicexchanger"s risks associated with money laundering. Here are collected and summarized the main points related to domestic politics. This is an incomplete document. To obtain a complete document, you need to contact the service of the Company, which is engaged in customer support.

Nicexchanger legal documents on domestic and international regulation should contain such procedures and schemes that will most effectively prevent processes related to money laundering, encouragement of terrorist activities, the spread of drugs and weapons that pose a danger to the people, the prosperity of bribes, human trafficking, acceptance necessary measures in cases where the actions of the Clients become suspicious.

The AML / KYC policy includes the ability to carry out the following actions:

1. Designate employees responsible for ensuring that anti-money laundering (AMLCO) measures are followed, and that employees are informed about the need to record suspicious manipulations by clients.
2. Determine the responsibilities of management and, as often as necessary, provide information on the risks of money laundering.
3. Train staff on anti-money laundering schemes.
4. Document and update the policy, all anti-money laundering tools used.
5. Create the conditions so that the risks associated with money laundering are constantly taken into account in the conduct of business.
6. Report any suspicion to the authorized structures.
7. Respond quickly to the response from the authorized structure.

 2. Basic principles

If the company has a new Client, then before starting the execution of a transaction of any kind, several important steps must be taken:

• carry out the KYC procedure, in particular, identification;
• keep records, identify and monitor transactions that are suspicious, unusual;
• inform all employees about their duties and all operations carried out by the company;
• properly train personnel;
• if requests come from external sources, then they should be sent to AMLCO.

3. Identity verification rules

When the company receives documentation that reflects information about a new Client, which may be an individual or a legal entity, it is important that the identity is fully confirmed. The client really has to be who he claims to be. The company is responsible for ensuring that the verification has been carried out correctly, even though information may come from other sources. The verification carried out must be satisfactory.

The information identifying the Client is subject to collection, storage, transfer and protection in accordance with the established Privacy Policy, which is in force in the company and complies with the requirements of the GDPR.

4. An employee authorized to monitor the implementation of measures related to combating money laundering

 AMLCO confirms its responsibility for the fact that the company will comply with all regulations regarding KYC. The person authorized to enforce the established rules, together with AMLCO, are related to the same person, but play a different role in the overall process.

It has already been said that AMLCO is a person who specializes in performing specific duties and has access to the information necessary for its activities.

To contact the AMLCO department, it is enough to send an electronic letter to the following address: [email protected].

 5. Transaction tracking system

Effective control in the company is carried out through constant verification of the risks associated with money laundering and financing of terrorist activities.

AMLCO is responsible for how the continuous monitoring of all the operations carried out by the company is maintained and implemented.

 6. Assessment of possible risks

The company is authorized to prescribe certain procedures and measures, apply schemes that allow to correctly assess possible risks, focus on those areas that are most exposed to the risk of money laundering and the development of terrorist activities.

Also an important function of AMLCO is the implementation of continuous monitoring and assessment of the effect of the procedures and measures established by the Policy.

The company has adopted a risk-oriented scheme described in the Policy. It is characterized by such moments:

• recognition that the risks associated with the possibility of financial laundering operations may differ depending on what services and financial instruments are used, in which countries this occurs and which Clients cooperate with the company;
• allowing members of the Board of Directors to differentiate Clients in accordance with the type of business and associated risks;
• allowing members of the Board of Directors to use their own schemes, with the help of which measures and methods of control are developed based on certain circumstances and characteristics of the Company;
• help in creating a system that will be less expensive;
• assistance in prioritizing specific actions and measures that respond to suspicious actions when using the company"s services associated with the risk of money laundering and the development of terrorist activities.

The scheme, created on the basis of assessing possible risks, which is described in the Policy, contains such assessment methods that are most effective for identifying possible risks associated with money laundering and the development of terrorism.

7. Prohibitions

If certain individuals / legal entities, as well as countries, are subject to international sanctions, the company cannot cooperate with them.

8. Countries banned

If persons live in countries blacklisted due to activities related to money laundering, or they provide illegal, prohibited services, then the company cannot cooperate with them.

The full version of the Anti-Money Laundering Policy contains a complete list of such countries. To get acquainted with it, you need to make a request to Nicexchanger. By decision of AMLCO, this list is periodically updated.