Summary of Anti-Money Laundering and Know Your Customer Policy

To monitor the accordance with EU directives and recommendations of FATF, B2BX Digital Exchange OU (working under trade name B2BinPay) has established a Compliance department responsible for Anti-money laundering and Know your customer (AML & KYC) procedures, obligatory for all employees and determining the policy of engagement with any company which uses B2BinPay service.

This summary describes base points of Company’s internal AML policy:

B2BX Digital Exchange follows a strong process of KYC verification in order to collect and check all required information about the client and persons in corporate structure. Opening anonymous accounts is restricted. Upon the request of the Company additional documents and information should be provided by the client. Refuse to provide documents on Company’s compliance request may lead to suspending or termination of relationships with the Company. Filling of respective KYC questionnaire, passing liveness check and videoverification are also an obligatory requirements of Company.

B2BX Digital Exchange verifies client bank’s reputation, geographic location and license. The client is allowed to declare only one bank account for transactions, and all deposits and withdrawals are allowed only from/to the declared account. The Company performs real-time checks of transactions. In case of the evidence or signs of suspicious transactions at the client’s account, cash or crypto replenishments from untrusted sources and / or any actions with attributes of fraud, the Company reserves the right to conduct an internal investigation, to block or close the Customer’s Account, cancel any payment and to suspend providing services.

B2BX Digital Exchange is protected against involvement in money laundering and terrorist financing through the screening of all clients (including controllers and beneficial owners), including sanctions screening. The Company also has an overall obligation to hold adequate and up to date information on clients’ beneficial ownership and conducts regular re-checks on clients and their activity.

The Company doesn’t provide services to the persons who located at the jurisdictions that are identified by the EU and FATF as high risk and non-cooperative jurisdictions having strategic AML/CFT deficiencies, according to official lists (including Iran, North Korea, etc.). Moreover, the Company doesn’t provide services to citizens and residents of U.S.A.

The Company applies a Risk Based Approach across the business, this requires identification, assessment, understanding and mitigation of AML/CTF risk including considering risk factors such as customer, product, geography and channel.