Anti-Money Laundering Policy

This AML Policy was published on 6 March 2024.

FIDGYTEX Sp. z o.o. (or “the Company”) Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designed to prevent and mitigate possible risks of the Company being involved in any kind of illegal activity. This document is a short extract of key principles from the Company’s Internal Policy and should not be viewed as a full AML/KYC Policy.

Global rules mandate the Company to put into place efficient internal protocols and systems to thwart terrorist funding, money laundering, illicit drug trafficking, human smuggling, proliferation of weapons of mass devastation, bribery and corruption, and to act accordingly in the face of any kind of suspicious activities from its customers.

The AML/KYC Policy covers the following matters:

• appointing an Anti-Money Laundering Compliance Officer (AMLCO) and making sure that employees know to report any suspicious activity to them;
• identifying the responsibilities of senior managers and providing them with regular information on money laundering risks;
• introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day business operations;
• documenting and updating anti-money laundering policies, controls and procedures;
• training employees on their anti-money laundering responsibilities;
• promptly responding to all communication from the appropriate authority;
• forwarding/reporting all substantiated suspicions to the appropriate authority.

GENERAL REQUIREMENTS FOR THE COMPANY

Before engaging in any business dealings with a fresh customer, the Company must ensure that a series of steps are taken and performed:

• AML procedures, including customer identification, record-keeping, discovering and monitoring of unusual or suspicious transactions and, as appropriate, internal/external reporting and control;
• ensuring that all employees know and understand their responsibilities and the Company’s procedures;
• ensure that appropriate training is undertaken;
• all relevant requests from outside sources are forwarded directly to the AMLCO.

IDENTITY VERIFICATION

Each time the Company asks for and receives evidence that affirms a new customer’s identity, it needs to be completely confident that the documents prove the customer is a real individual or company and they are who they say they are. While the Company may sometimes refer to external sources as part of its vetting process when signing up customers, it has the ultimate legal accountability for the inspections being done correctly. The client’s identification data will be obtained, kept secure, shared and secured in line with the Company’s Privacy Policy and related regulations that meet the GDPR guidelines.

ANTI-MONEY LAUNDERING COMPLIANCE OFFICER

The AMLCO is ultimately responsible for implementing regulations concerning Anti-Money Laundering. For the sake of ease of navigating this document ‘Compliance Officer’ and ‘AMLCO’ refer to the same person; however, the specific tasks of each role are different.

As noted above, the AMLCO is a person of authority with access to any and all relevant information for the performance of their duties. You can contact the Company’s AMLCO department via email: [email protected].

TRANSACTION MONITORING

The constant monitoring of the Users’ transactions is an imperative element in effectively controlling the risk of Money Laundering and Terrorist Financing. In this respect, the AMLCO shall be responsible for maintaining as well as developing the ongoing monitoring process of the Company.

RISK ASSESSMENT

The Company will execute applicable practices and processes by utilizing a risk-oriented approach, aiming to concentrate its efforts in the areas where the potential for Money Laundering and Terrorist Financing appears to be greater.

Further, the AMLCO shall monitor and evaluate the effectiveness of the measures and procedures of this Policy on an ongoing basis. The adopted risk-based approach that is followed by the Company and described in the full AML Policy has the following general characteristics:

• recognizes that the money-laundering or terrorist financing threat varies across clients, countries, services and financial instruments;
• allows the board of directors to differentiate between clients of the Company in a way that matches the risk of their particular business;
• allows the board to apply its own approach in formulation of policies, procedures and controls in response to the Company’s particular circumstances and characteristics;
• helps to produce a more cost-effective and efficient system;
• promotes prioritization of efforts and actions of the Company in response to the likelihood of Money Laundering and Terrorist Financing occurring through the use of the Company’s services. The risk-based approach adopted by the Company, and described in the Policy, involves specific measures and procedures in assessing the most cost effective and appropriate way to identify and manage the Money Laundering and Terrorist Financing risks faced by the Company.

SANCTIONS

The Company is prohibited from transacting with individuals, companies and countries that are under international sanctions. The Company will therefore screen all new and existing clients against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

The Company does not provide services to persons residing in:

• USA
• Japan
• Austria
• Afghanistan
• Bosnia and Herzegovina
• Burundi
• Iraq
• Central African Republic
• Congo
• Guinea
• Guinea-Bissau
• Syria
• Haiti
• Lebanon
• Libya
• Mali
• Iran
• North Korea
• British Columbia
• Quebec
• Myanmar
• Nicaragua
• Serbia
• Somalia
• South Sudan
• Sudan
• Tunisia
• Yemen
• Russia
• Zimbabwe

The above list may be updated at any time with or without updating this document by a decision of the Compliance Officer.