AML policy

1. ABOUT THE COMPANY 

1.1 This AML Policy is applicable to Polish legal entity Monteris Sp. zo.o., operating through coinsdrom.com, a company organised under the laws of the Republic of Poland, with its registered address at Hoża Street 86, Unit 210, 00-682 Warsaw, Poland, Number KRS: 0001101442, a Virtual Asset Service Provider under applicable Polish law and anti-money laundering regulations, registered in the Register of Activities in the Field of Virtual Currencies (RDWW) under registration number RDWW-1285. (hereinafter – the Company)

2. AML/CTF COMMITMENT

2.1 Money laundering (ML) and terrorist financing (TF) continue to pose substantial challenges to the integrity and stability of the crypto-asset sector. The Company acknowledges the serious risks that ML and TF activities present to its business operations, reputation, and the wider financial ecosystem. In alignment with the legislative frameworks of the European Union, the company has developed and implemented a robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy.

2.2 This Policy is grounded in binding legal obligations, supervisory expectations, and internationally recognised standards and best practices. Through this framework, the Company ensures that effective controls, monitoring mechanisms, and risk-based measures are in place to detect, prevent, and report any suspicious activities. The company remains firmly committed to maintaining the highest standards of transparency, accountability, and regulatory compliance in the provision of its virtual-asset services.

3. LEGAL AND REGULATORY FRAMEWORK

3.1 This AML/CTF Policy is implemented in accordance with:

3.1.1 The Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (Journal of Laws of the Republic of Poland 2025, as amended);

3.1.2 Regulations issued under the Polish AML Act, including those relating to transaction reporting and identification obligations;

3.1.3 Guidelines and communications issued by the General Inspector of Financial Information (GIIF);

3.1.4 European Union Anti-Money Laundering Directives;

3.1.5. The Financial Action Task Force (FATF) Recommendations;

3.1.6 European Banking Authority (EBA) AML/CTF Guidelines, where applicable;

3.1.7 Applicable European Union restrictive measures and sanctions regulations;

3.1.8 Other applicable laws and regulations of the Republic of Poland and the European Union.

4. AML/CTF POLICY OVERVIEW

4.1 The AML/CTF Policy establishes internal procedures and control measures for identifying, assessing, managing, and mitigating ML/TF risks. It includes client due diligence (CDD), enhanced due diligence (EDD), ongoing due diligence (ODD), sanctions screening,  transaction monitoring, and reporting of suspicious activities. 

5. CUSTOMER RESPONSIBILITIES AND OBLIGATIONS 

5.1 The Company is committed to ensuring a secure and compliant buy and sell services environment in line with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. To maintain the integrity of our services, all customers must adhere to the following operational rules:

5.1.1 No Cash Purchases or Sales: The Company does not accept cash for performing the Exchange Order. All transactions must be conducted using digital means to ensure traceability and transparency.

5.1.2 No Third-Party Transactions: The Company does not accept deposits from third parties into a user’s profile, nor does it allow profile management by third parties. Additionally, we do not support joint or shared profiles, ensuring that all accounts remain strictly personal and private.

5.1.3 Service Restrictions to Personal Wallets Only: the Company provides buy and sell services exclusively to customers’ personal wallet addresses. Transactions to or from third-party wallets are prohibited, ensuring that each transaction is conducted by the account holder themselves.

5.1.4 Documentation Requirements: the Company maintains strict documentation standards. We do not allow exceptions regarding the documents required from users. All customers are required to provide accurate and legitimate identification and supporting documents for verification purposes.

5.1.5 Right to Refuse Transactions: The Company reserves the right to refuse any transaction if there is any suspicion of involvement in Money Laundering (ML) or Terrorist Financing (TF). – Transactions will be monitored for suspicious activity, and the company retains the right to act in accordance with its regulatory obligations to protect the system from illicit activity.

5.1.6 Suspicious Activity Reporting: In accordance with applicable AML/CTF laws and regulatory obligations, The Company is not obligated to inform customers if their behavior is reported as suspicious to the relevant authorities. As part of our compliance framework, any suspicious activity may be reported to the appropriate authorities, and actions may be taken without prior customer notification.

6. KNOW YOUR CUSTOMER (KYC) AND DUE DILIGENCE

6.1 The Company applies a structured and risk-based KYC process for all clients, in accordance with the relevant AML/CFT regulations. We are required to verify the identity of every individual authorized to transact on our platform beyond a reasonable doubt.

6.2 To ensure this, customers must complete an automated identity verification process, which includes biometric checks comparing the ID photo to a live image. This process is supported by trusted external providers. If the verification is inconclusive, our compliance or support team may conduct a manual review and request additional information.

6.3 If we are unable to confirm the authenticity and ownership of submitted documents, access to services will be restricted.

6.4 Ongoing due diligence, including monitoring and periodic reviews, is performed based on each customer’s risk profile. Enhanced Due Diligence (EDD) is applied in cases that present elevated risk, including but not limited to Politically Exposed Persons (PEPs), adverse media findings, and high-risk jurisdictions. Business relationships shall not be established or continued where the risk level is deemed unacceptable. This approach ensures the integrity and compliance of our operations.

6.5 Customer due diligence measures are applied in accordance with Articles 34–46 of the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, taking into account the risk-based approach. 

7. SANCTIONED COUNTRIES AND HIGH-RISK JURISDICTIONS

7.1 Sanctions Compliance: The Company complies with all applicable European Union restrictive measures, United Nations sanctions, and other sanctions applicable under Polish law, including measures enforced by the General Inspector of Financial Information (GIIF). As part of our AML/CTF compliance, we do not process transactions from countries subject to sanctions or jurisdictions identified as high risk for money laundering or terrorist financing.

7.2 High-Risk Jurisdictions: We also take into consideration countries with significant AML/CTF risks, such as those identified by FATF, European Commission, and those with weak regulatory frameworks. Customers from such jurisdictions may be subject to enhanced due diligence, or their access to services may be restricted.

7.3 Suspicious Activity and Transactions: Transactions flagged as suspicious or those originating from high-risk jurisdictions will be subject to further scrutiny and, if necessary, suspended or reported to relevant authorities.

8. TRANSACTION MONITORING

8.1 As part of its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework, the Company actively monitors customer activity to detect and assess any potentially suspicious behavior or transactions. In accordance with regulatory requirements, any identified suspicions are promptly reported to the relevant authorities.

8.2 The Company complies with mandatory reporting thresholds and implements safeguards to prevent tipping off or compromising any ongoing investigations. All processes are handled in line with internal procedures and applicable laws to ensure full regulatory compliance.

8.3 Transaction monitoring is conducted in accordance with the internal procedure for monitoring transactions and reporting suspicious transactions, implemented pursuant to Articles 72–86 of the Polish AML Act. Transactions that are unusual, lack economic justification, involve significant amounts, or present heightened ML/TF risk are subject to enhanced scrutiny. 

9. REPORTING OBLIGATIONS

9.1 In accordance with the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, the Company promptly reports any suspicious transactions or activities to the General Inspector of Financial Information (GIIF).

9.2 Where the Company has a justified suspicion that a transaction or assets may be related to money laundering or terrorist financing, the notification is submitted immediately via the GIIF electronic reporting system.

9.3 The Company complies with statutory reporting thresholds, including the obligation, where applicable, to report transactions with an equivalent value exceeding EUR 15,000, within the time limits prescribed by law.

9.4 The Company ensures strict confidentiality of all reports and fully observes the prohibition on tipping-off. 

10. STAFF TRAINING 

10.1 To ensure that all employees and individuals acting on behalf of the Company are equipped with the knowledge to meet the regulatory requirements, the Company conducts regular training on Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Sanctions compliance. This training ensures that all staff members who interact with customers or monitor transactions understand their responsibilities in customer identification, reporting suspicious activity, and maintaining accurate records. The Company is committed to maintaining a well-informed workforce to uphold the highest standards of compliance and security.

11. POLICY REVIEW AND UPDATES

11.1 The Company’s AML/CTF Policy is subject to regular review to ensure its continued effectiveness and compliance with applicable laws and regulations. The Policy is reviewed at least annually and whenever required by amendments to the Polish AML Act, GIIF guidance, or changes to the Company’s risk profile. This ongoing process ensures that the Company remains fully aligned with evolving regulatory frameworks and industry best practices.

12. CONTACT INFORMATION FOR COMPLIANCE INQUIRIES

12.1 For AML/CTF-related matters, please contact our AML Department at: [email protected]