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AML Policy

Introduction

  1. CoinHub OJSC (hereinafter referred to as the Company), registered under the laws of the Kyrgyz Republic. This AML/KYC/CTF Policy (the "AML Policy) sets forth the rules and procedures followed by the Company to detect and prevent any financial crimes.

    The Company is firmly committed to preventing the use of its operations for money laundering or any activity that facilitates

    money laundering, or the financing of terrorist or criminal activities.

    These procedures are managed by the Chief Compliance Officer and his team, collectively referred to as the Compliance Department. The Compliance Department is responsible for monitoring compliance with relevant AML/CFT procedures.

    Protection Measures

    The Company has implemented protection measures that protect it from engaging in any suspicious financial activity by:

    1. Conducting KYC procedures for Users – individuals and legal entities;
    2. Conducting an enterprise-wide risk assessment to determine the Company's risk profile; 3) Implementation of internal

    procedures, policies, and virtual assets controls aimed at mitigating the risks of money laundering and terrorist financing;

    1. Conducting AML/CFT training for staff;
    2. Conducting periodic AML audits;
    3. Maintaining and updating information on Users;
    4. Reporting suspicious transactions to the relevant financial authority.

    KYC Measures

    As part of user due diligence, the Company must:

    1. Identify the User or their representative and verify the information provided using reliable, independent sources, including using

    virtual assets of electronic identification and trust services for electronic transactions;

    1. Confirm the authenticity of documents and information provided by Users;
    2. Investigate Users whose activity has been identified as suspicious or risky;
    3. Request additional and/or updated documents and information from Users when deemed necessary by the Company;
    4. Identify Users on an ongoing basis, even if Users have been identified in the past. Risk Factors and Risk Assessment

    To conduct due diligence on Users, the Company reserves the right to request documents and information, including, but not limited to:

    1. Name (for individuals), business name and names of directors or other representatives (for legal entities);
    2. Date of birth (for individuals), date of incorporation and company number (for legal entities). individuals);
    3. Country of residence/citizenship (for individuals)/registration address (for legal entities);
    4. Residential address and proof of address;
    5. Email address;
    6. Government-issued identification document;
    7. Source of virtual assets;
    8. Any other document/information requested by the Company.

    User Due Diligence Levels

    Verification levels perform the following functions:

    1. Providing access to certain types of deposits and withdrawals of virtual assets;
    2. Increasing limits on deposits/withdrawals of virtual assets.

    The level of verification performed on the User will affect the number of actions the User can perform on the JSC CoinHub.

    KYC verification levels are an integral part of CoinHub's policy. AML and are available on the website.

    Regulatory Framework

    • Regulations and regulations of national legislation on countering the financing of terrorism (CFT) and the proliferation of weapons of mass destruction.
    • International conventions and resolutions, including FATF recommendations.
    • Regulations on inclusion of persons in lists related to extremism and terrorism.

    Comparison with lists

    • Comparison of client data with information from:
    • National list of persons involved in terrorist and extremist activities.
    • International sanctions lists (UN, FATF, etc.).

    Requested Information

    The requested information and documents form an integral part of the CoinHub JSC AML Policy

    Certain information will be automatically collected from documents provided by the User. The Company reserves the right to request any additional documents and/or information at any time.

    Monitoring Requirements

    The Company continuously monitors activities to prevent money laundering and terrorism. financing and other illegal activities.

    As part of its monitoring requirements, the Company must:

    1. Verify transactions on the Platform;
    2. Request documents, if necessary, to

    update/confirm the information collected when applying for customer due diligence measures;

    1. If necessary, indicate the source of the User's virtual assets;
    2. Pay particular attention to transactions made by Users from high-risk countries.

    Detecting Suspicious Activity

    If the Company detects suspicious transactions, as specified in its internal policies and procedures, it must conduct additional inquiry regarding the User's activity and request any additional documents that may be required.

    JSC "CoinHub" The Company reserves the right to verify your identity at any time for compliance with the Anti-Money Laundering Act or any other applicable law.

    Reporting Suspicious Activity

    If the User fails to provide information and an explanation about a suspicious transaction, a full set of requested documents, or submits suspicious or unusual documents that the Company cannot verify, and the Company reasonably suspects that the User's actions may be related to money laundering, terrorist financing, or other illegal activity, the Company reserves the right to suspend the account of the User suspected of such activity at its sole discretion.

    If you have any additional questions regarding the AML/KYC/CTF procedures conducted at CoinHub OJSC, please contact us at: Kyrgyz Republic, Leninsky District, Pavlova Street, Bldg. 19. Phone: 996 (703) 27-69-36.

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