Blockchain and Crypto Technology Limited Liability Company (B&CT LLC)
Anti-Money Laundering Compliance Programme

Firm Policy

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the 4th Anti- Money Laundering Directive (4AMLD) as amended by Directive 2018/843 of the European Parliament and of the Council of 30 th May 2018, The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, Proceeds of Crime Act 2002, Terrorism Act 2000, Criminal Finances Act 2017, Terrorist Asset- Freezing etc. ,Act 2010, Anti-terrorism, Crime and Security Act 2001, Counter-terrorism Act 2008, Schedule 7 and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveller’s cheques, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cybercrime and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable 4th Anti-Money Laundering Directive (4AMLD) as amended by Directive 2018/843, The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 requirements and will be reviewed and updated on a regular basis to ensure, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

This document contains information on the following rules and procedures:

• Procedures for the application of due diligence measures regarding customers;
• Determination of the customer’s risk profile;
• Procedures in case of suspicion of money laundering and terrorist financing;
• Procedures for data retention and making data available;
• Instructions for identifying whether a person is a politically exposed person; and
• Instructions for effectively identifying whether a person is subject to international sanctions or a person whose place of residence or seat is in a high-risk third country or country that meets the criteria specified in MLRs 2017.

AML Compliance Officer/MLRO Duties

The duties of the AML Compliance Officer/MLRO will include, inter alia:

• Developing and implementing Business Strategy in accordance with Money Laundering and Terrorist Financing Prevention Act and regulatory rules,
• Monitoring the firm’s compliance with AML obligations,
• Overseeing communication and training for employees,
• Handling regulatory enquiries, examinations and cooperating in internal audit,
• Liaising with NCA on any regulatory matter, liaising with external service providers and consultants,
• Instructions for effectively identifying whether a person is subject to international sanctions or a person whose place of residence or seat is in a high-risk third country or country that meets the criteria specified in MLRs 2017.
• monitoring and updating of internal policies, procedures and controls ensuring consistency within the operation of the business with company standards and any regulatory obligations
• Ensuring performance of CDD (Customer Due Diligence) checks.

The AML Compliance Officer will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SAR) are reported to the National Crime Agency (NCA) when appropriate.

The AML Compliance Officer is vested with full responsibility and authority to enforce the firm’s AML programme.

Shell Banks

‘Shell bank’ means a credit institution or financial institution, or an institution that carries out activities equivalent to those carried out by credit institutions and financial institutions, incorporated in a jurisdiction in which it has no physical presence, involving meaningful mind and management, and which is unaffiliated with a regulated credit or financial group.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must not enter into a correspondent relationship with a shell bank. It also will take appropriate measures to ensure that it does not enter into or continue a correspondent relationship with a bank that is known to allow its accounts to be used by a shell bank.

Customer Due Diligence (CDD)

“Customer due diligence (CDD)” means measures intended for identifying the customer and its beneficial owner, verifying their identity, and obtaining information on the purpose and intended nature of the business relationship.

Customer due diligence is a key element in the framework for combating money laundering and terrorist financing as it ensures that company knows who it is dealing with, is able to prevent criminal undertakings from using its services and can identify and mitigate any money laundering and terrorist financing risks associated with customer relationships.

a) Timing of customer due diligence

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must apply customer due diligence measures:

• Upon establishment of a business relationship (opening an account);
• Upon making or mediating occasional transactions (if any) outside a business relationship that amounts to a transfer of funds exceeding 1,000 euros;
• Upon verification of information gathered while applying due diligence measures or in the case of doubts as to the sufficiency or truthfulness of the documents or data gathered earlier while updating the relevant data;
• Upon suspicion of money laundering or terrorist financing, regardless of any derogations, exceptions or limits provided for in the MLRs 2017.

The verification of the identity of the customer and the beneficial owner, must take place before the establishment of a business relationship.

Before establishing a business relationship with:

• A company which is subject to the requirements of Part 21A of the Companies Act 2006 (information about people with significant control);
• An unregistered company which is subject to the requirements of the Unregistered Companies Regulations 2009;
• A limited liability partnership which is subject to the requirements of the Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009; or an eligible Scottish partnership which is subject to the requirements of the Scottish Partnerships (Register of People with Significant Control) Regulations 2017.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must collect proof of registration or an excerpt of the register from the company, the unregistered company or the limited liability partnership (as the case may be) or from the registrar (in the case of an eligible Scottish partnership).

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must report to the registrar any discrepancy it finds between information relating to the beneficial ownership of the customer:
- which it collects under paragraphs (1) - (4) above,
- which otherwise becomes available to BLOCKCHAIN&CRYPTO TEHNOLOGY LLS in the course of carrying out its duties under the MLR 2017.

BLOCKCHAIN&CRYPTO TEHNOLOGY LLS is not required under paragraph to report information which it would be entitled to refuse to provide on grounds of legal professional privilege in the High Court (or in Scotland, on the ground of confidentiality of communications in the Court of Session).

b) CDD measures

BLOCKCHAIN&CRYPTO TEHNOLOGY LLS identifies the customer by obtaining a range of information about him. The verification of the identity consists of the verifying some of this information against documents or information obtained from a reliable source which is independent of the customer.

Customer due diligence measures include the following:

• Identifying the customer and/or customer’s representative, and verifying his identity;
• Identifying the beneficial owner, where relevant, and, for the purpose of verifying their identity, taking measures to the extent that allows the company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer;
• Assessing, and where appropriate obtaining information on, the purpose and intended nature of the business relationship or transaction;
• Gathering information on whether a person is a politically exposed person, their family member or a person known to be close associate;
• Monitoring of a business relationship.

c) Identification and verification of natural person

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will collect the following information for all accounts, if applicable, for any natural person that is opening a new account and whose name is on the account:

• Name;
• Personal identification code or, if none, the date and place of birth and the place of residence or seat;
• Information on the identification and verification of the right of representation and scope thereof and, where the right of representation does not arise from law, the name of the document serving as the basis for the right of representation, the date of issue, and the name of the issuer.

These documents are accepted for the verification of identity (name, date and place of birth):

• An identity card;
• A residence permit card;
• Citizen’s passport;
• A diplomatic passport
• An alien’s passport;
• A travel document for a refugee;
• A valid travel document issued in a foreign country;
• A valid driving licence if the name,
• Photograph or facial image, signature or image of signature and date of birth or personal identification code of the holder are entered therein.

Where the original document specified above is not available, the identity can be verified on the basis of a document specified above, which has been authenticated by a notary or certified by a notary or officially, or on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.

A document submitted for identification must be assessed as follows:

• Validity of the document based on the date of expiry;
• The outward likeness and age of the person match the appearance of the person represented on the document (in case of face-to-face or video identification);
• The personal identification code matches the gender and age of the submitter; and
• With respect to information contained in codes assigned to individuals of a foreign country, foreign missions or other competent authorities must be consulted in the case of doubt as to the authenticity of the document or identity.

These documents are accepted for the verification of address:

• Driving license (only if it has not been used for identity verification);
• Utility bill (gas, electricity, water, landline telephone, etc.) not older than 3 months;
• Bank or building society statement, or;
• Tenancy agreement with the recent payment confirmation.

In addition to the address of the place of residence of the individual, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC may record other contact details, including an e-mail address, phone number, Facebook account, Skype account and other similar data, and agree on the submission of information.

d) Identification and verification of legal person

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will collect the following information for all accounts, if applicable, for any legal person that is opening a new account and whose name is on the account:

• The name or business name of the legal person;
• The registry code or registration number and the date of registration;
• The address of registered office, and if different, its principal place of business;
• The names of the director, members of the management board or other body replacing the management board, and their authorisation in representing the legal person;
• The law to which the legal person is subject, and its constitution (whether set out in its articles of association or other governing documents);
• Identify the beneficial owner; take reasonable measures to verify the identity of the beneficial owner so that the company is satisfied that it knows who the beneficial owner is;
• The details of the telecommunications of the legal person.

These documents are accepted for the verification of identity:

• The registry card of the relevant register;
• The registration certificate of the relevant register, or
• A document equal to the documents specified above.

Where the original document specified above of this section is not available, the identity can be verified on the basis of a document specified above, which has been authenticated by a notary or certified by a notary or officially, or on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.

Where the customer is a legal person, trust, company, foundation or similar legal arrangement the company must take reasonable measures to understand the ownership and control structure of that legal person, trust, company, foundation or similar legal arrangement.

A representative of a legal person of a foreign country must, at the request of the company, submit a document certifying his or her powers, which has been authenticated by a notary or in accordance with an equal procedure and legal ised or certified by a certificate replacing legal is ation (apostille), unless otherwise provided for in an international agreement.

Overall set of required documents for identification of a legal person is established in the table 1 below. The number and type of documents can vary depending on the legal person’s country of registration.

Table 1. The list of documents for CDD of a legal person

e) Identification of Beneficial Owners

‘Beneficial owner’ means a natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or otherwise exercises control over a transaction, act, action, operation or step or over another person and in whose interests or favour or on whose account a transaction or act, action, operation or step is made.

In respect of natural person, the customer himself is the beneficial owner, unless there are features of the transaction, or surrounding circumstances, that indicate otherwise. Therefore, there is no requirement on company to make proactive searches for beneficial owners in such cases, but BLOCKCHAIN&CRYPTO TECHNOLOGY LLC should make appropriate enquiries where it appears that the customer is not acting on his own behalf.

In the case of a body corporate which is not a company whose securities are listed on a regulated market, beneficial owner means:

• Any individual who exercises ultimate control over the management of the body corporate;
• Any individual who ultimately owns or controls (in each case whether directly or indirectly), including through bearer share holdings or by other means, more than 25% of the shares or voting rights in the body corporate or an individual who controls the body corporate.

An individual controls a body corporate if:

• The body corporate is a company or a limited liability partnership and that individual satisfies one or more of the conditions set out in Part 1 of Schedule 1A to the Companies Act 2006 (people with significant control over a company); or
• The body corporate would be a subsidiary undertaking of the individual (if the individual was an undertaking) under section 1162 (parent and subsidiary undertakings) of the Companies Act 2006 read with Schedule 7 to that Act.

In the case of a partnership (other than a limited liability partnership), beneficial owner means any individual who:

• Ultimately is entitled to or controls (in each case whether directly or indirectly) more than 25% share of the capital or profits of the partnership or more than 25% of the voting rights in the partnership;
• Satisfies one or more the conditions set out in Part 1 of Schedule 1 to the Scottish Partnerships (Register of People with Significant Control) Regulations 2017 (references to people with significant control over an eligible Scottish partnership); or
• Otherwise exercises ultimate control over the management of the partnership.

Where, after all possible means of identification have been exhausted, the beneficial owner of the company cannot be identified and there is no doubt that such person exists or where there are doubts as to whether the identified person is a beneficial owner, the natural person who holds the position of a senior managing official is deemed as a beneficial owner.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must register and keep records of all actions taken in order to identify the beneficial owner.

In the case of a trusts, foundation or other legal arrangement similar to a trust, the beneficial owner means:

• The settlor;
• The trustees;
• The beneficiaries;
• Where the individuals (or some of the individuals) benefiting from the trust have not been determined, the class of persons in whose main interest the trust is set up, or operates;
• Any individual who has control over the trust, where ‘control’ means a power (whether exercisable alone, jointly with another person or with the consent of another person) under the trust instrument or by law to:
  • Dispose of, advance, lend, invest, pay or apply trust property;
  • Vary or terminate the trust;
  • Add or remove a person as a beneficiary or to or from a class of beneficiaries;
  • Appoint or remove trustees or give another individual control over the trust;
  • Direct, with hold consent to or veto the exercise of a power mentioned above.

Beneficial owner, in any other case, means the individual who ultimately owns or controls the entity or arrangement or on whose behalf a transaction is being conducted.

This section does not apply to a company listed on a regulated market that is subject to disclosure requirements consistent with European Union law or subject to equivalent international standards which ensure adequate transparency of ownership information.

f) Consequences of impossibility to identify person, their representative or beneficial owner

If BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is unable to comply with the due diligence measures provided for in this section or where it suspects money laundering or terrorist financing, BLOCKCHAIN&CRYPTO TEHNOLOGY LLS is prohibited to establish a business relationship or allow for making or closing an occasional transaction (if any).

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is also prohibited to establish a business relationship or make a transaction with a person whose capital consists of bearer shares or other bearer securities.

Where BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has a business relationship with a customer in a situation provided above in this subsection, the refusal by the customer to provide information or documents required for the application of due diligence measures is deemed a fundamental breach of the contract and BLOCKCHAIN&CRYPTO TEHNOLOGY LLS has the right to terminate the contract serving.

Simplified Customer Due Diligence (SDD)

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC may apply SDD measures in relation to a particular business relationship if it determines that, taking into account its risk assessment, the business relationship presents a low degree of risk of money laundering and terrorist financing.

a) Conditions of application of simplified due diligence measure:

• Adjusting the timing of CDD, such as the identity of a customer or of the customer’s representative may be verified on the basis of information obtained from a credible and independent source also at the time of establishment of the business relationship, provided that it is necessary for not disturbing the ordinary course of business. In such an event the verification of identity must be carried out as quickly as possible and before the taking of binding measures.;
• In relation of clauses 2-4 of section b. CDD measures - choosing the extent of performance of the duty and the need to verify the information and data used therefore with the help of a credible and independent source.;
• A factor characterising a lower risk has been established and at least the following criteria are met:
• A long-term contract has been concluded with the customer in writing, electronic all yor in a form reproducible in writing;
• Payments accrue to BLOCKCHAIN&CRYPTO TECHNOLOGY LLC in the framework of the business relationship only via an account held in a credit institution or the branch of a foreign credit institution registered in the UK commercial register or in a credit institution established or having its place of business in a contracting state of the European Economic Area or in a country that applies requirements equal to those of Directive (EU) 2015/849 of the European Parliament and of the Council;
• The total value of incoming and outgoing payments in transactions made in the framework of the business relationship does not exceed 15 000 euros a year.

b) Factors Characterising lower risk

Before the application of simplified due diligence measures, factors referring to a lower risks should be taken into account and BLOCKCHAIN&CRYPTO TEHNOLOGY LLS should determine whether these factors will be implemented on the whole, in part or as separate grounds.

The following is deemed a situation reducing risks relating to the customer type:

• The customer is a company listed on a regulated market, which is subject to disclosure obligations that establish requirements for ensuring sufficient transparency regarding the beneficial owners a public administration, or
• A publicly owned enterprise;
• The customer is a credit institution or financial institution located in a contracting state of the European Economic Area or a third country, which in its country of location is subject to requirements equal to those established in Directive (EU) 2015/849 of the European Parliament and of the Council and subject to state supervision;
• A person who is a resident of a country or geographic area having the characteristics specified as following:
• An EEA state;
• A third country that has effective AML/CFT systems;
• A third country where, according to credible sources, the level of corruption and other criminal activity is low;
• A third country where, according to credible sources such as mutual evaluations, reports or published follow-up reports, AML/CFT requirements that are in accordance with the updated recommendations of the Financial Action Task Force (FATF), and where the requirements are effectively implemented.

Enhanced Customer Due Diligence (EDD)

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must apply EDD measures in order to adequately manage and mitigate a higher-than- usual risk of money laundering and terrorist financing.

EDD measures must be applied to manage and mitigate the risks arising:

• In any case identified as one where there is a high risk of money laundering or terrorist financing, as a result of risk assessment by BLOCKCHAIN&CRYPTO TECHNOLOGY LLC, or in information made available to BLOCKCHAIN&CRYPTO TECHNOLOGY LLC;
• In any business relationship with a person established in a high-risk third country or in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country;
• In relation to correspondent relationships with a credit institution or a financial institution;
• If BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has determined that a customer or potential customer is a PEP, or a family member or known close associate of a PEP;
• In any case where BLOCKCHAIN&CRYPTO TEHNOLOGY LLS discovers that a customer has provided false or stolen identification documentation or information and it proposes to continue to deal with that customer; in any case where: o a transaction is complex and unusually large, o the reisanunusualp atter noftr an sanctions, and, o the transaction or transactions have no apparentecon omicor legal purpose, and in any other case which by its nature can present a higher risk of money laundering or terrorist financing.

A “high-risk third country” means a country which has been identified by the European Commission in delegated acts adopted under Article 9.2 of the fourth money laundering directive as a high-risk third country.

A “relevant transaction” means a transaction in relation to which BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is required to apply customer due diligence measures.

Being “established in” a country means:

• In the case of a legal person, being incorporated in or having its principal place of business in that country, or
• In the case of a financial institution or a credit institution, having its principal regulatory authority in that country; and
• In the case of an individual, being resident in that country, but not merely having been born in that country.

a) Factors characterising higher risk

Upon assessment of factors referring to a higher risk, the following is deemed a situation increasing risks related to the customer as a person:

• The business relationship foundations based on unusual factors, including in the event of complex and unusually large transactions and unusual transaction patterns that do not have a reasonable, clear economic or lawful purpose or that are not characteristic of the given business specifics;
• The customer is a resident of a higher-risk geographic area;
• The customer is a legal person or a legal arrangement, which is engaged in holding personal assets;
• The customer is a cash-intensive business;
• The customer is a company that has nominee shareholders or bearer shares or a company whose affiliate has nominee shareholders or bearer shares; the ownership structure of the customer company appears unusual or
• Excessively complex, given the nature of the company’s business.

Upon assessment of factors referring to a higher risk, in particular the following is deemed a situation increasing risks related to the product, service, transaction or delivery channel:

• Private banking;
• Provision of a product or making or mediating of a transaction that might favour anonymity;
• Payments received from unknown or unassociated third parties;
• A business relationship or transaction that is established or initiated in a manner whereby the customer, the customer’s representative or party to the transaction is not met physically in the same place (non face-to-face);
• The service involves the provision of nominee directors, nominee shareholders or shadow directors, or the formation of companies in a third country;
• New products and new business practices, including new delivery mechanism, and the use of new or developing technologies for both new and pre-existing products.

Upon assessment of factors referring to a higher risk, in particular as situation where the customer, a person involved in the transaction or the transaction itself is connected with a following country or jurisdiction is deemed a factor increasing the geographical risk:

• That, according to credible sources such as mutual evaluations, detailed evaluation reports or published follow-up reports, has not established effective AML/CFT systems;
• That, according to credible sources, has significant levels of corruption or other criminal activity, such as terrorism (within the meaning of section 1 of the Terrorism Act 2000(a)), money laundering, and the production and supply of illicit drugs;
• That is subject to sanctions, embargos or similar measures issued by, for example, the European Union or the United Nations; that provides funding or support for terrorist activities, or that has designated terrorist organisations operating within their country, as identified
• By the European Union or the United Nations; countries that have organisations operating within their territory which have been designated:
  • By the government of the United Kingdom as a proscribed organisation under Schedule 2 to the Terrorism Act 2000(a), or
  • By other countries, international organisations, or the European Union as terrorist organisations;
• Countries identified by credible sources, such as evaluations, detailed assessment reports, or published follow-up reports published by the Financial Action Task Force, the International Monetary Fund, the World Bank, the Organisation for Economic Cooperation and Development, or other international bodies or non-governmental organisations as not implementing requirements to counter money laundering and terrorist financing that are consistent with the recommendations published by the Financial Action Task Force in February 2012 and updated in June 2019.

In making the assessment, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must bear in mind that the presence of one or more risk factors may not always indicate that there is a high risk of money laundering or terrorist financing in a particular situation.

b) Additional due diligence measures

In the case of a business relationship or transaction with a person established in a high-risk third country the enhanced due diligence measures taken by BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must include:

• Obtaining additional information on the customer and on the customer’s beneficial owner;
• Obtaining additional information on the intended nature of the business relationship;
• Obtaining information on the source of funds and source of wealth of the customer and of the customer’s beneficial owner;
• Obtaining information on the reasons for the transactions;
• Obtaining the approval of senior management for establishing or continuing the business relationship;
• Conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.

In the case a transaction is complex and unusually large, there is an unusual pattern of transactions, and, the transaction or transactions have no apparent economic or legal purpose, the enhanced due diligence measures taken by BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must include:

• As far as reasonably possible, examining the background and purpose of the transaction, and
• Increasing the degree and nature of monitoring of the business relationship in which the transaction is made to determine whether that transaction or that relationship appear to be suspicious.

Depending on the requirements of the case, the enhanced customer due diligence measures may also include, among other things:

• Seeking additional independent, reliable sources to verify information provided or made available to BLOCKCHAIN&CRYPTO TECHNOLOGY LLC;
• Taking further steps to be satisfied that the transaction is consistent with the purpose and intended nature of the business relationship;
• Increasing the monitoring of the business relationship, including greater scrutiny of transactions;
• Taking additional measures to understand better the background, ownership and financial situation of the customer, and other parties to the transaction.

Origin of funds is how the customer got the funds, for example from selling a property, an inheritance payment or a divorce settlement. Source of funds means the details of the bank account that the funds come from.

These documents are accepted for the identifying the origin of the funds:

Savings from salary (basic and/or bonus):

• Original or certified copy of a payslip (or bonus payment);
• Letter from employer confirming salary;
• Latest audited accounts (if self-employed) and company bank statement;

Sales of Shares or Other Investments / Liquidation of Investment Portfolio:

• Certified investment/savings certificates, contract notes or cash-in statements
• Bank statement clearly showing receipt of funds and investment company name
• Signed letter detailing funds from a regulated accountant

Sale of Property:

• Signed letter from solicitor
• Certified copy of sale contract
• Signed letter from estate agent

Inheritance:

• Grant of probate (with a copy of the will), which must include the value of the estate
• Signed letter from solicitor

Company Sale:

• Signed letter from solicitor or regulated accountant
• Copy of contract of sale, plus bank statement showing proceeds
• Copies of media coverage (if applicable) as supporting evidence

Company Profit:

• Certified copy of latest audited company accounts

Gift:

• Donor’s source of wealth (requirements of evidence as stated above for each individual source of wealth) and a letter from the donor confirming details of the gift

Cmpetition or gambling win:

• A signed letter from the organisation providing the proceeds of the winon letter-headed paper confirming name of winner, date of win and value of winnings;
• Bank statement showing deposit of winnings in customer’s name and referencing the organisation providing the proceeds of win;
• Media coverage of the win showing name of winner, date of win and value of winnings;

Maturing policy, policy claim, replacement policy:

• Letter from product provider regarding notification of proceeds of claim under the policy;
• Closing statement from product provider;

Compensation:

• Letter or court order from compensating body;
• Signed letter from solicitor/lawyer hand ling the compensation;

Loan:

• A signed letter from the lender on letter-headed paper confirming the name of borrower, amount of loan and date of draw-down;
• A loan statement confirming the details;

Other:

• Appropriate, independent supporting documentation;
• Signed letter from a person with personal knowledge of the activities described and in a position subject to anti-money laundering regulation, e.g. a regulated accountant or lawyer.

These documents are accepted for the identifying the source of the funds:

• Credit institution account statement;
• A signed letter from the credit institution on letter-headed paper confirming name and bank account details.

c) Enhanced due diligence measures applied to transaction made with natural and legal persons operating in high-risk third country

Where BLOCKCHAIN&CRYPTO TECHNOLOGY LLC comes in contact with a high-risk third country via a person participating in a transaction made in the obliged entity’s economic or professional activities, via a person participating in a professional act, via a person using a professional service or via a customer, it applies the following due diligence measures:

• Gathering additional information about the customer and its beneficial owner;
• Gathering additional information on the planned substance of the business relationship;
• Gathering information on the origin of the funds and wealth of the customer and its beneficial owner;
• Gathering information on the underlying reasons of planned or executed transactions;
• Receiving permission from the senior management to establish or continue a business relationship;
• Improving the monitoring of a business relationship by increasing the number and frequency of the applied control measures and by choosing transaction indicators that are additionally verified;
• Ensuring that a customer makes a payment from an account held in the customer’s name in a credit institution of a contracting state of the European Economic Area or in a third country that implements requirements equal to those of Directive (EU) 2015/849 of the European Parliament and of the Council

Politically exposed persons (PEP)

MLRs 2017 requires to have proper systems and procedures in place to determine whether a customer or the beneficial owner of a customer is:

• A politically exposed person (a “PEP”); or
• A family member or a known close associate of a PEP

‘Politically exposed person’ means a natural person who is or who is entrusted with prominent public functions, other than as a middle-ranking or more junior official, including:

• A head of State, head of government, minister and deputy or assistant minister;
• A member of parliament or of a similar legislative body;
• A member of a governing body of a political party;
• A member of a supreme court, of constitutional courts or of any judicial body the decisions of which are not subject to further appeal except in exceptional circumstances;
• A member of a court of auditors or of the board of a central bank;
• An ambassador, a chargé d'affaires and a high-ranking officer in the armed forces;
• A member of an administrative, management or supervisory body of a State- owned enterprise;
• A director, deputy director and member of the board or equivalent function of an international organisation.

‘Family member’ means the spouse or civil partner of the PEP, children of the PEP and the spouses or civil partners of the PEP’s children; parents of the PEP.

‘Known close associate’ means a natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations, with a PEP; and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a PEP.

For the purpose of deciding whether a person is a known close associate of a politically exposed person, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC only have regard to information, which is in its possession, or to credible information which is publicly available.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC when proposes to have, or to continue, a business relationship with a PEP, or a family member or a known close associate of a PEP, must, in addition to other enhanced due diligence measures:

• Have approval from senior management for establishing or continuing the business relationship with that person;
• Take adequate measures to establish the source of wealth and source of funds which are involved in the proposed business relationship or transactions with that person; and
• where the business relationship is entered into, conduct enhanced ongoing monitoring of the business relationship with that person.

Where a person who was a PEP is no longer entrusted with a prominent public function, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must continue to apply the requirements set out above in relation to that person:

• For a period of at least 12 months after the date on which that person ceased to be entrusted with that public function; or
• Or such longer period as BLOCKCHAIN&CRYPTO TECHNOLOGY LLC considers appropriate to address risks of money laundering or terrorist financing in relation to that person.

When a person who was a PEP is no longer entrusted with a prominent public function, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is no longer required to apply the requirements set out above in relation to a family member or known close associate of that PEP (whether or not the period referred above has expired).

PEPs are aware that their status as a PEP may facilitate the detection of their illicit behaviour. This means that PEPs may attempt to shield their identity, to prevent detection.

a) Red flags and indicat or srelating to the PEP and his/her behaviour

Specific behaviour and individual characteristics of PEPs may raise red flags/risk levels or cause a suspicion:

• Use of corporate vehicles (legal entities and legal arrangements) to obscure ownership involved industries; or countries;
• Use of intermediaries when this does not match with normal business practices or when this seems to be used to shield identity of PEP;
• Use of family members or close associates as legal owner;
• The PEP makes inquiries about the company’s AML policy or PEP policy;
• The information that is provided by the PEP is inconsistent with other publicly available information, such as asset declarations and published official salaries;
• The PEP is unable or reluctant to explain the reason for doing business in the country of the financial institution;
• The PEP provides inaccurate or incomplete information;
• Funds are moved to and from countries to which the PEPs does not seem to have ties with;
• The PEP is or has been denied entry to the country (visa denial);
• the PEP is from a country that prohibits or restricts its/certain citizens to hold accounts or own certain property in a foreign country.

b) Transactions with politically exposed person

In a situation where a customer or customer’s beneficial owner is a politically exposed person, a family member of a politically exposed person or a person known to be a close associate of a politically exposed person, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC applies enhanced due diligence measures (section 7 of this policy) including the following that are mandatory:

• Obtains approval from the senior management to establish or continue a business relationship with the person;
• Applies measures to establish the origin of the wealth of the person and the sources of the funds that are used in the business relationship or upon making occasional transactions (if any);
• Monitors the business relationship in an enhanced manner.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC does not need to apply the due diligence measures provided for in this section with regard to a local politically exposed person, their family member or a person known to be their close associate where there are no other factors that refer to a higher-than-usual risk.

c) PEP screening

For the PEP screening BLOCKCHAIN&CRYPTO TECHNOLOGY LLC uses a reliable source https://sumsub.com

PEP screening is conducted both at the customer on-boarding stage and within the ongoing monitoring process in accordance with the time schedule applied to customer based on its risk level.

Customer risk classification

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC uses a risk based approach to classify the customer risk level and categorizes 4 levels of risks as shown in Table 2.

The risk based approach includes evaluation of the following risk indicators: or natural person:

Table 2. Customer risk levels and DD conditions applied

The risk is low - there are no risk factors of impact in any risk category and the customer and the customer’s operations are transparent and do not deviate from the operations of an average, reasonable person engaged in the same field. Thereby there is no suspicion that the risk factors on the whole might cause the realisation of the threat of money laundering or terrorist financing.

The risk is medium - there is one risk factor or there are several risk factors in the risk category, which differ(s) from the operations of a person engaged in the same field, but the operations are still transparent. Thereby there is no suspicion that the risk factors could, on the whole, cause realisation of the threat of money laundering or terrorist financing.

The risk is high or extra high - there is one feature or there are several features in the risk category which, on the whole, undermine the transparency of the person and the person’s operations, as a result of which the person differs from a person operating in the same field. Thereby the realisation of the threat of money laundering or terrorist financing is at least possible.

Financial Sanctions

EU financial sanctions (including where they implement UN sanctions) apply within the territory of the EU and to all EU persons, wherever they are in the world. UK financial sanctions apply within the territory of the UK and to all UK persons, wherever they are in the world.

All individuals and legal entities who are within or undertake activities within the UK’s territory must comply with the EU and UK financial sanctions that are in force. All UK nationals and UK legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place.

OFSI works closely with the EU Commission and other member states in implementing sanctions. The UK imposes sanctions applied by the UN and EU as well as a limited number of its own sanctions (e.g. Terrorist Asset- Freezing etc. Act 2010).

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must report to OFSI as soon as practicable if it knows or has reasonable cause to suspect that a designated person has committed an offence.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC should report any transactions carried out for persons subject to sanctions or if they try to use BLOCKCHAIN&CRYPTO TECHNOLOGY LLC ’s services.

Suspected breach reporting and related information can be found on the Office of Financial Sanctions Implementation section of HM Treasury website at link: https://www.gov.uk/

Sanction screening

For the sanction screening BLOCKCHAIN&CRYPTO TEHNOLOGY LLS uses a reliable source Sum&Substance (https://sumsub.com/ ). Sum&Substance has integrated the following sanction lists into its system:

• UK Financial Sanctions (HMT)
• EU Financial Sanctions (EU)
• United Nations Sanctions (UN)
• OFAC - Specially Designated Nationals (SDN)
• US Consolidated Sanctions
• Bureau of Industry and Security (US)
• Office of the Superintendent of Financial Institutions (Canada)
• Australian Sanctions
• Department of State, AECA Debarred List (US)
• Department of State, Non-proliferation Sanctions (US)

Sanction screening is conducted both at the customer onboarding stage and within the ongoing monitoring process in accordance with the time schedule applied to customer based on its risk level.

If a similar matching result is found, the EDD is applied to the customer and it is added to internal watch list in order to carry out enhanced ongoing monitoring. If an exact matching result is found, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC makes a disclosure to the relevant authority (Office of Financial Sanctions Implementation, or NCA, or both) and block the customer in our operational system until consent is given to proceed or refuse. In addition, we may cease the business relationship with the customer.

If BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has doubts that a person, who is in business relations or is making a transaction or carrying out a proceeding with it, as well as a person intending to create business relations, make a transaction or carry out a proceeding with it, is a subject of international financial sanction, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC shall immediately notify the NCA of the identification of the doubt thereof and of the measures taken.

Conduct in Case of Suspicion of Money Laundering and Terrorist Financing (Suspicious Activity Report)

The background of each individual suspect or unusual instance must be investigated as much as reasonably necessary, thereby recording the details of the transaction and analysing the circumstances with the aim of identifying the typical features of more frequent transactions.

The main circumstances to which attention should be paid when suspect and unusual transactions are analysed are as follows:

• What is suspicious about the steps, transactions or other circumstances?
• Is BLOCKCHAIN&CRYPTO TECHNOLOGY LLC convinced that it knows its customer sufficiently or is it necessary to collect additional information about the customer?
• Upon taking a step or making a transaction involving identifying a customer or the customer’s representative, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must make certain that it follows the prescribed procedure. Was all the required information submitted or did additional information need to be requested or otherwise clarified?
• Have there been repeated instances of suspicious steps and transactions?

a) Internal reporting

All employees must report any activity that they see in the course of their duties and that they think may be suspicious to the Compliance Officer; all such reports must be documented by the employee making the report. BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will provide all necessary training and guidance to ensure that the employees are aware of:

• Their obligations in this area;
• Possible offences and penalties;
• Procedures to be followed;
• Documentation to be used to make reports, and where to receive further advice and guidance.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has made a SAR template (see Annex 1) available to all staff, all reports must be made using this template to ensure consistency. Reports must be submitted by the employees to the Compliance Officer as soon as possible but not later than 24 hours from the moment when an employee detected the suspicious activity/transaction.

All employees shall respond in full to all enquiries made by the Compliance Officer for the purposes of evaluating report filing.

The Compliance Officer will acknowledge every report received and will then conduct his own evaluation of the information provided within the report and decide whether or not to make a notification to the NCA.

b) Duty to report to NCA in case of suspicion of money laundering and terrorist financing

Where BLOCKCHAIN&CRYPTO TECHNOLOGY LLC identifies in economic or professional activities, a professional act or provision of a professional service an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or to the commission of related offences or an attempt thereof or with regard to which BLOCKCHAIN&CRYPTO TECHNOLOGY LLC suspects or knows that it constitutes money laundering or terrorist financing or the commission of related offences, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must report it to the NCA immediately.

Where BLOCKCHAIN&CRYPTO TECHNOLOGY LLC suspects or knows that terrorist financing or money laundering or related criminal offences are being committed, the making of the transaction or professional act or the provision of the official service must be postponed until the submission of a report to NCA.

Transactions that are suspicious must be reported if the Company knows, suspects or has a reason to suspect, that the transaction or linked transactions:

• Involve funds derived from illegal activity or intended or conducted in order to hide or disguise funds or assets derived from illegal activity.
• Designed to evade the reporting requirements, whether through structuring or other means.
• Serves no business or apparent lawful purpose and BLOCKCHAIN&CRYPTO TECHNOLOGY LLC knows of no reasonable explanation for the transaction after examining all available facts.
• Involves any other use of BLOCKCHAIN&CRYPTO TECHNOLOGY LLC or its services to facilitate criminal activity.

Where relevant, the NCA gives feedback on their performance of the duty to report and on the use of the received information.

c) Place and form of performance of duty to report to NCA

If a particular transaction or activity raises suspicions of money laundering or terrorist financing, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC should not proceed without getting consent from NCA.

A Suspicious Activity Report can be sent to NCA:

• Electronically;
• By fax;
• By first class post or courier;
• Submit a Suspicious Activity Report online using the NCA online system on their website (preferred).

Guidance on submitting a suspicious activity report (SAR) online can be found on the NCA website https://www.nationalcrimeagency.gov.uk/

d) Confidentiality of report

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will maintain strictly confidential any SAR and its supporting documentation. We will NOT notify any person involved in the transaction that the transaction has been reported. In general, disclosure of the fact that a SAR filing is contemplated or has been made is a violation of the law. Except where disclosure is requested by NCA or other appropriate law enforcement or regulatory authority.

e) NCA’s feedback on reporting

The NCA will respond within 7 days of receiving the Suspicious Activity Report. BLOCKCHAIN&CRYPTO TECHNOLOGY LLC can proceed with the transaction or activity if it does not receive a decision from the NCA within 7 working days from when they received the request. BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will not be committing an offence because consent is automatically assumed in law if no decision has been received after 7 working days.

If BLOCKCHAIN&CRYPTO TECHNOLOGY LLC does get a decision within 7 days but the NCA does not give BLOCKCHAIN&CRYPTO TECHNOLOGY LLC permission to proceed, they have a further 31 calendar days to take action. If after that further 31 days BLOCKCHAIN&CRYPTO TECHNOLOGY LLC have not heard anything from the NCA, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC can proceed if it wants to. It won’t be committing an offence.

Ongoing monitoring

It is a regulatory requirement that company conducts ongoing monitoring of a business relationship on a risk-sensitive and appropriate basis.

Monitoring customer activity helps identify unusual activity. If unusual activities cannot be rationally explained, they may involve money laundering or terrorist financing. Monitoring customer activity and transactions that take place throughout a relationship helps BLOCKCHAIN&CRYPTO TECHNOLOGY LLC know its customers, assist it to assess risk and provides greater assurance that the company is not being used for the purposes of financial crime.

Monitoring is based on a considered identification of transaction characteristics, such as:

• The unusual nature of a transaction;
• The nature of a series of transactions;
• The geographic destination or origin of a payment;
• Higher risk customer relationships require enhanced ongoing monitoring. This will generally mean more frequent or intensive monitoring.

For these purposes the monitoring of a business relationship includes at least the following:

• Checking of transactions made in a business relationship in order ensure that the transactions are in concert with BLOCKCHAIN&CRYPTO TECHNOLOGY LLC knowledge of the customer, its activities and risk profile;
• Regular updating of relevant documents, data or information gathered in the course of application of due diligence measures;
• Identifying the source and origin of the funds used in a transaction;
• In economic or professional activities, paying more attention to transactions made in the business relationship, the activities of the customer and circumstances that refer to a criminal activity, money laundering or terrorist financing or that a likely to be linked with money laundering or terrorist financing, including to complex, high-value and unusual transactions and transaction patterns that do not have a reasonable or visible economic or lawful purpose or that are not characteristic of the given business specifics;
• In economic or professional activities, paying more attention to the business relationship or transaction whereby the customer is from a high-risk third country or a country or territory specified in subsection a of section 7 of this document or whereby the customer is a citizen of such country or whereby the customer’s place of residence or seat or the seat of the payment service provider of the payee is in such country or territory.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will conduct the following types of ongoing monitoring:

• Real-time monitoring by reliable independent service provider, which is able to do real- time fraud analysis, post-query alerts, data points to inform manual review and custom rule creation;
• Post-transaction monitoring by BLOCKCHAIN&CRYPTO TEHNOLOGY LLS responsible person by way of independent review of the activities that a customer has undertaken.

A list of typical parameters on the basis of which transactions can be selected for post- transaction monitoring is given below (the list is not exhaustive):

• Single large international payments (e.g. whereby the sum ends with at least four zeros);
• Accounts (of individuals and legal entities) with the highest turnover in the period under review;
• The largest transactions (of individuals and legal entities) in the period under review (of individuals and legal entities) based on different currencies;
• Single transactions that exceed the limit, which are made by customers whose turnover is small
• Transactions with persons whose country of operation or origin is on the list of higher (terrorist);
• Risk countries and transactions of specific customers or customer types.

Staff training

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must:

• Take appropriate measures to ensure that its relevant employees are:
  • Made aware of the law relating to money laundering and terrorist financing, and to the requirements of data protection, which are relevant to the implementation of this Policy and MLR 2017; and
  • Regularly given training in how to recognize and deal with transactions and other activities or situations which may be related to money laundering or terrorist financing;
• Maintain a record in writing of the measures taken under the paragraph above, and in particular, of the training given to its relevant employees.

For the purposes of the above paragraph, a relevant employee is an employee whose work is:

• Relevant to the BLOCKCHAIN&CRYPTO TECHNOLOGY LLC compliance with any requirement in the MLR 2017, or otherwise capable of contributing to the:
  • Identification or mitigation of the risk of money laundering and terrorist financing to which BLOCKCHAIN&CRYPTO TECHNOLOGY LLC business is subject; or
  • Prevention or detection of money laundering and terrorist financing in relation to BLOCKCHAIN&CRYPTO TECHNOLOGY LLC business.

Record keeping

It is a regulatory requirement that company retains records gathered during the customer onboarding, transaction performance, course of business relationship and ongoing monitoring process of a business relationship.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC will retain the documents and data specified in this section in a manner that allows for exhaustively and immediately replying to the enquiries of the Financial Intelligence Units or, in accordance with legislation, those of other supervisory authorities, investigative bodies or courts, inter alia, regarding whether BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has or has had in the preceding five years a business relationship with the given person and what is or was the nature of the relationship.

The period of five years begins on the date on which BLOCKCHAIN&CRYPTO TECHNOLOGY LLC knows, or has reasonable grounds:

• that the transaction is complete, for records relating to an occasional transaction; or
• that the business relationship has come to an end for records relating to:
  • any transaction which occurs as part of a business relationship, or
  • customer due diligence measures taken in connection with that relationship.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is not required to keep the records of any transaction which occurs as part of a business relationship for more than 10 years.

Once the period, has expired, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must delete any personal data obtained for the purposes of the MLR 2017 requirements unless:

• BLOCKCHAIN&CRYPTO TECHNOLOGY LLC is required to retain records containing personal data:
  • by or under any enactment, or for the purposes of any court proceedings;
  • the data subject has given consent to the retention of that data; or
  • BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has reasonable grounds for believing that records containing the personal data need to be retained for the purpose of legal proceedings.

a) CDD documents and records

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must retain copies of the documents gathered during the customer due diligence process, which serve as the basis for identification and verification of persons, and the documents serving as the basis for the establishment of a business relationship no less than five years after termination of the business relationship.

These will additionally include:

• records in writing of all the actions BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has taken to identify the beneficial owner of the body corporate;
• where, after all possible means of identification of beneficial owner have been exhausted and BLOCKCHAIN&CRYPTO TECHNOLOGY LLC treats the senior person in that body corporate responsible for managing it as its beneficial owner, BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must keep records in writing of all the actions BLOCKCHAIN&CRYPTO TECHNOLOGY LLChas taken in doing so, and any difficulties BLOCKCHAIN&CRYPTO TECHNOLOGY LLC has encountered in doing so.

b) Documents and records gathered during the course of business relationship

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must retain the entire correspondence relating to the performance of the duties and obligations arising from the MLR 2017 and all the data and documents gathered in the course of monitoring the business relationship as well as data on suspicious or unusual transactions or circumstances which the NCA was not notified of no less than five years after termination of the business relationship with a customer.

c) Registration and transaction details

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must retain registration and transaction details no less than five years after termination of the business relationship. It includes:

• Transaction date or period and a description of the substance of the transaction;
• Information on the circumstance of the obliged entity’s refusal to establish a business relationship or make an occasional transaction (if any);
• the circumstances of a waiver to establish a business relationship or make a transaction, including, an occasional transaction (if any), on the initiative of a person participating in the transaction or professional act, a person using the official service or a customer where the waiver is related to the application of due diligence measures by BLOCKCHAIN&CRYPTO TECHNOLOGY LLC;
• Information according to which it is not possible to take the due diligence measures provided for in subsection using information technology means;
• Information on the circumstances of termination of a business relationship in connection with the impossibility of application of the due diligence measures;
• Transaction amount, the currency and the account number.

d) Suspicious activity notification records (notification to NCA)

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must retain the documents prepared with regard to a transaction on any data medium and the documents and data serving as the basis for the notification obligations specified in section 11 of this document for no less than five years after making the transaction or performing the duty to report.

e) Policies, controls and procedures

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must maintain a record in writing of the policies, risk assessment, controls and procedures established any changes to those policies, controls and procedures made as a result of the review and update; and the steps taken to communicate those policies, controls and procedures, or any changes to them, within BLOCKCHAIN&CRYPTO TECHNOLOGY LLC business.

f) Training records

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC must maintain a record in writing of the measures taken under Section 13 of this Policy.

Revising of Anti-Money Laundering (AML) Programme: Compliance and Supervisory Rules and Procedures

This document will be reviewed on an annual basis by the Compliance Officer, or more frequently in the event of any changes to the environment or circumstances affecting the company’s exposure to money laundering related risks, terrorist financing, or other related financial crimes in the course of the BLOCKCHAIN&CRYPTO TECHNOLOGY LLC activities.

BLOCKCHAIN&CRYPTO TECHNOLOGY LLC trading as B&C T is registered in Republic of Kyrgyzstan, Bishkek, Leninsky dist., 240, Chokmorova str. Registration number 216057-3301-OOO https://bct.kg/

Any amendment to the document will be developed by the Compliance Officer and will be brought before the management board for approval. Compliance Officer will call the management board meeting and the management board will decide whether to approve the amendments by simple majority voting.

In the event that there’s no properly appointed management board in the company, the Compliance Officer will be authorised to introduce any amendments to this Anti-Money Laundering (AML) Programme in his/her sole discretion.