Anti-Money Laundry and Know Your Customer Policy

This Anti-Money Laundry and Know Your Customer Policy (hereinafter - the “Policy”) is designated to prevent and mitigate possible risks of C3EXCHANGE OÜ being involved in any kind of illegal activity.

C3EXCHANGE OÜ implements effective own internal procedures and instruments to prevent illegal transfer of assets, drug, human, organ and any other illegal trafficking, poaching, pornography, trade in arms, terrorism and crime financing, corruption and bribery, money laundering, and takes action in case of any form of suspicious activity from its Users.

This Policy includes verification procedures, compliance officer, monitoring of transactions, risk assessment.

1. VERIFICATION OF USERS

1.1. One of the international standards for preventing illegal activity is customer due diligence. According to customer due diligence, C3EXCHANGE OÜ establishes its own verification procedures within the standards of “Know Your Customer” frameworks.

1.2. C3EXCHANGE OÜ identity verification procedure requires the User to provide C3EXCHANGE OÜ with reliable, independent source documents, data or information. For such purposes, C3EXCHANGE OÜ reserves the right to collect User’s identification information for the purposes of the Policy.

1.3. C3EXCHANGE OÜ will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and C3EXCHANGE OÜ reserves the right to investigate certain Users who have been determined to be risky or suspicious.

1.4. C3EXCHANGE OÜ reserves the right to verify User’s identity on an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). Service can identify an activity as suspicious on its sole discretion.

1.5. C3EXCHANGE OÜ reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

1.6. User’s identification information will be collected, stored, shared and protected strictly in accordance with the C3EXCHANGE OÜ Privacy Policy.

2. PAYMENT AND TRANSACTIONS PROCESSING

2.1. C3EXCHANGE OÜ strictly prohibits using the Service through anonymous proxy-servers, or any other anonymous Internet connections.

2.2. In order to prevent possible unlawful transactions C3EXCHANGE OÜ requires the sender of the payment must be the same person as the payee. Any payments in favor of a third party are strictly prohibited.

2.3. While using card payments C3EXCHANGE OÜ accepts only the cards with 3d Secure tool.

3. COMPLIANCE OFFICER

3.1. The Compliance Officer is the person, duly authorized by C3EXCHANGE OÜ, whose duty is to ensure the effective implementation and enforcement of the Policy. The Compliance Officer is obliged to have relevant education and specific knowledge and expertise in AML fundamental and practical issues.

3.2. It is the Compliance Officer’s responsibility to supervise all aspects of implementing the Policy including but not limited to: collecting Users’ identification information; establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations; monitoring the transfer of assets and investigating any significant deviations from normal transfer activity; implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; updating risk assessment regularly.

3.3. The Compliance Officer is entitled to interact with competent authorities, involved in the prevention of all types of illegal activity.

4. MONITORING OF TRANSACTIONS

4.1. In order to prevent unlawful activity, C3EXCHANGE OÜ also uses the internal automated system analyzing transactions and users’ behavior, blocking any suspicious activity; sets limits on users’ transactions; observes the Know-Your-Customer policy; performs verification of the data provided by the User, employing any available means. C3EXCHANGE OÜ analyses what the Users do on the platform. Therefore, C3EXCHANGE OÜ relies on data analysis as a risk-assessment and suspicion detection tool. C3EXCHANGE OÜ may perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting.

4.2. C3EXCHANGE OÜ always uses the block chain monitoring tool if the amount of deposit and withdrawal transaction done by the User is equivalent or more than 1 BTC in any cryptocurrency.

4.3. C3EXCHANGE OÜ always provides specific verification and manual processing of withdrawal transactions on the amount of more than 2 BTC.

4.4. Monitoring system functionalities also include: aggregating transfers of assets by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal сase and document management.

4.5. With regard to the Policy, C3EXCHANGE OÜ will monitor all transfers of assets and it reserves the right to: ensure that transfers of assets of suspicious nature are reported to the proper competent authority through the Compliance Officer; request the User to provide any additional information and documents in case of suspicious transfers of assets; suspend or terminate User’s Account when C3EXCHANGE OÜ has a reasonable suspicion that such User engaged in illegal activity.

4.6. C3EXCHANGE OÜ sets limits on withdrawal of funds and the User may be limited in initiating withdrawal of funds earlier than 3 (three) days after the registration of the new User, changes in the user's account data, including changing or recovering the password, and changing the authorization method.

4.7. Use of the Service for purposes other than that provided for in the User Agreement, in particular for the deposit and withdrawal of funds without trading transactions, may also be deemed a suspicious transaction and is prohibited by the User.

4.8. The above list is not exhaustive, and the Internal Control Specialist will monitor the Transactions of the Users daily to determine whether to report such transactions and treat them as suspicious or should be considered conscientious.

5. RISK ASSESSMENT

C3EXCHANGE OÜ, in line with the international requirements, has adopted a risk-based principle to combating money laundering and terrorist financing. This makes C3EXCHANGE OÜ to be able to ensure that measures to prevent an illegal activity are commensurate with the identified risks. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.