Anti-Money Laundering Policy

AlfaBit warns users against using this Service for money laundering, terrorism financing, illegal activities of any kind, and against using this Service to purchase illegal goods and/or services.

Money laundering - is concealing an illicit source of money by converting it into cash or investments that appear to be legitimate.

General Provisions

In order to prevent transactions of an illegal nature, the Service establishes certain requirements for all Orders created by the User:

• The sender and recipient of the Order Payment must be the same person. Transfers in favor of third parties using the Service are strictly prohibited.

• All the contact information, which the User enters in the Order, as well as other personal data, transferred by the User to the Service, must be up to date and completely accurate.

• It is strictly forbidden to create Orders by the User using anonymous proxy-servers or any other anonymous connections to the Internet.

This anti-money laundering policy (hereinafter "AML Policy") describes the procedures and mechanisms used by the AlfaBit Service to combat money laundering. AlfaBit adheres to the following rules:

• not engage in business relationships with known criminals and/or terrorists;

• not to process transactions that are the result of known criminal and/or terrorist activities;

• not facilitate any transactions involving known criminal and/or terrorist activity;

• has the right to restrict or prohibit the use of all or part of the services for citizens of such countries as Afghanistan, Russian Federation, Bosnia and Herzegovina, USA, Democratic People's Republic of Korea, Democratic Republic of Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, Lao People's Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, Ukraine.

Verification procedures

AlfaBit establishes its own verification procedures as part of the anti-money laundering standards - "Know Your Customer" (KYC) policy.

Users of the Service go through a verification procedure (they provide the state identification document: passport or ID card). AlfaBit reserves the right to collect identification information of Users for the purposes of implementing the AML Policy. This information is processed and stored strictly according to AlfaBit's Privacy Policy and Personal Data Processing Policy.

The Service may also request a second document to identify the User: a bank statement or utility bill no older than 3 months specifying the User's full name and actual place of residence. The Service also has the right to request photo/video verification of the customer if there is a suspicion of dishonesty of the information provided.

The Service checks the authenticity of documents and information provided by users and reserves the right to receive additional information about users who have been identified as dangerous or suspicious.

If a User's identification information has been changed or their activity appears suspicious, the AlfaBit Service has the right to request updated documents from the User, even if they have been authenticated in the past.

Responsible for Compliance with AML Policy

The AML Policy Compliance Officer is an AlfaBit employee whose responsibility is to ensure compliance with AML policy, namely:

• collecting Users' identifying information and submitting it to the responsible personal data processing agent;

• creating and updating internal policies and procedures for writing, reviewing, submitting and maintaining all reports required by existing laws and regulations;

• monitoring transactions and analyzing any significant deviations from normal User activity;

• implementing a records management system to store and retrieve documents, files, forms and logs;

• regularly updating risk assessment policy.

The AML Policy Compliance Officer is authorized to interact with law enforcement agencies that are engaged in preventing money laundering, terrorist financing, and other illegal activities.

Transaction Monitoring

Monitoring of user transactions and analysis of received data is also a tool of risk assessment and detection of suspicious transactions. In case of suspected money laundering AlfaBit monitors all transactions and reserves the right to:

• report suspicious transactions to the appropriate law enforcement authorities;

• ask the User to provide any additional information and/or documents;

• suspend or terminate the User's account;

• suspend the exchange and freeze the assets until the circumstances are clarified;

• refund to the User by canceling the exchange procedure in accordance with the User Agreement;

• risk assessment.

The above list is not exhaustive. The AML Policy Compliance Officer monitors User transactions on a daily basis to determine whether they should be reported and treated as suspicious.

In accordance with international requirements, AlfaBit Service uses a risk-based approach to combat money laundering and terrorist financing. In this way, measures to prevent money laundering and terrorist financing are commensurate with the risks identified