AML/KYC Policy

1. Terms Of Use 2. Privacy Policy 3. AML/KYC Policy 4. Public Offer 5. Cookies Policy 6. Dispute Resolution 7. Risk Disclosure

Effective Date: 05.12.2024

Overview

Cvetpay UAB’s Anti-Money Laundering (AML) and Know Your Customer (KYC) policies are designed to comply with international and local regulations and to prevent the misuse of our platform for illicit purposes. Cvetpay UAB, registered in Lithuania (registration code 306920599), is located at Vilnius, A. Goštauto g. 8-224, LT-01108. Contact us at info@cvetpay.com.

Identity Verification

We require all users to verify their identity to comply with AML/KYC regulations. Customers must provide government-issued IDs (National ID, Passport, or Driver’s License) and a selfie. Enhanced checks are conducted for high-risk individuals, such as Politically Exposed Persons (PEPs), who must submit additional documents (e.g., utility bills) and complete video selfies. Verification services are conducted by Sum and Substance, our trusted third-party partner. The Company reserves the right to reverify identities if user information changes or appears suspicious. Failure to provide valid documentation may result in the denial of services.

Transaction Monitoring

We monitor all transactions to detect unusual or suspicious activities. This includes evaluating transaction size, frequency, and patterns. Suspicious transactions are flagged and reviewed by our Compliance Officer. If necessary, Suspicious Activity Reports (SARs) are filed with the relevant authorities in accordance with regulatory requirements. The Compliance Officer ensures timely and accurate reporting.

Risk Analysis

Cvetpay UAB assigns risk levels to customers using a standardized methodology. Customers are categorized as low, medium, or high risk based on factors such as transaction history, geography, and customer type. High-risk customers undergo enhanced due diligence to mitigate potential risks of fraud, money laundering, and terrorism financing.

Compliance with Sanctions

We screen all customers and transactions against international sanctions lists, including those maintained by the United Nations, European Union, and the United States. Cvetpay UAB does not conduct business with individuals, entities, or countries listed on these sanctions lists.

Data Retention

Customer information, including identity verification data and transaction records, is retained for a minimum of 5 years after the end of the customer relationship, as required by regulatory standards. After this period, data is securely deleted or anonymized, unless otherwise mandated by law.

Employee Training Programs

All employees undergo regular training to ensure compliance with AML/KYC regulations. Training includes: - Identifying suspicious activities. - Filing Suspicious Activity Reports (SARs). - Understanding KYC procedures and regulatory updates. These programs are conducted annually and updated to reflect new legal and procedural developments.

Vendor Due Diligence

Cvetpay UAB conducts due diligence on third-party vendors and partners to ensure compliance with AML requirements. Vendors are evaluated for their adherence to regulatory standards, and periodic reviews are conducted to verify ongoing compliance.

Policy Review and Updates

Our AML/KYC policies are reviewed annually or as required by changes in laws or regulations. Updates are documented and communicated to all relevant stakeholders to maintain compliance with the latest legal and industry standards.