Introduction

Within the scope of its business activities, the company Second February Limited (hereinafter “the Company”) provides services related to virtual assets (crypto assets).

The Company issues this binding document – Anti-Money Laundering and Countering the Financing of Terrorism COMPLIANCE POLICY – establishing the standards obligatory for the Company to efficiently reduce or eliminate illegal activities in full while providing its services to the customers. This goal is to be achieved by implementing and adhering to the FATF’s Standards for virtual assets as a priority.

Among the most crucial preventive measures the Company carries out are:

• customer due diligence (CDD),
• record keeping and
• suspicious transactions/activities monitoring and reporting (STR).

To prevent fraudulent activity, the Company performs monitoring of customers' activity within its system using both numerous automated mechanisms and IT solutions and manual checks.

The best practices to be implemented by the Company in its internal scrutiny procedures will contribute the belief that virtual asset technologies and businesses can continue to grow and innovate in a responsible way, and in its turn, it will contribute to creation of a level playing field.

The Company also implements sanction measures applied by the Republic of Seychelles in relation to quite a wide group of natural persons and legal entities. That means permanent checks whether a customer is subject to international sanctions or not, respectively fulfilment of other procedures as described in Company’s internal binding documents.

Customer Due Diligence (CDD)

1. The Company shall apply customer due diligence measures in respect of customers, business relationships and transactions, and conduct ongoing monitoring of business relationships.

2. To be able to establish the identity of its customers, the Company must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of Company pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. Company retains a right to re-establish the identity of the customer in cases where Company sees it fit and in relation to that requests additional data/documents/information or renew previously submitted.

Enhanced customer due diligence (EDD)

1. The Company applies on a risk-sensitive basis enhanced customer due diligence measures and enhanced ongoing monitoring in any situation which by its nature presents a higher risk of money laundering, terrorist financing activities or other criminal conduct on the basis of national risk assessment.

2. The Company, proportionate to risk, applies enhanced customer due diligence measures and enhanced ongoing monitoring in respect of business relationships and transactions with legal and natural persons from countries which do not apply or fully apply the Financial Action Task Force Recommendations.

3. Enhanced due diligence measures in business relationship monitoring include, among other things monitoring the business relationship more efficiently by increasing the number and frequency of applicable verification measures and selecting the transaction indicators that will be additionally checked.

Record keeping

1. The data and documents related to the business relationship shall be archived.

2. All records must be kept for a minimum period of seven (7) years from the date

   • of the relevant event;
   • of any transaction or correspondence relating to a customer;
   • on which evidence of a person’s identity is obtained;
   • in the case of an ongoing business relationship, after the business relationship ceases.

3. Records do not have to be kept in hard copy. Retention may be by way of original documents, or by way of copies in any machine-readable or electronic form from which a paper copy can be readily produced.

Suspicious transactions/activities monitoring and reporting (STR)

1. The Company shall conduct ongoing monitoring (check) of a business relationship.

2. In accordance with a Section 46(2) of the AML/CFT Act “ongoing monitoring” of a business relationship means —

   • (a) scrutinising transactions undertaken throughout the relationship to ensure that the transactions are consistent with a company knowledge of the customer, the business and risk profile and the source of funds of the customer; and
   • (b) keeping the documents, data or information obtained for the purpose of applying customer due diligence measures up to date.

3. Following its AML Policy and the applicable legal acts, Company, when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. Company will not disclose any information about such report to have been made and will not address any questions in relation to that.

4. The requirement to report suspicious transactions applies to all types of transactions or activities.

Sanctions and PEP monitoring

1. The Company is not allowed to:

   • conclude transactions with parties subject to the sanctions;
   • conclude transactions the execution of which would be in conflict with the sanctions;
   • perform the actions the performance of which is prohibited by the sanctions.

2. A Compliance officer shall be responsible for organization of implementation of the sanctions in accordance with the law of the Republic of Seychelles.

3. The Company implements the sanctions by using the sanctions screening tools, which automatically scans names of the clients in the system to find potential name matches.

4. The initial sanctions screening constitutes a part of the CDD. During a customer identification process the Company uses the sanctions screening tools to check whether sanctions are applied to the customer, their representatives, related persons and beneficial owners(s).

1.Before each transaction the Company should check if the transaction does not fall within the scope of sectorial sanctions.

1. In the course of business relationship, the Company shall perform sanctions screening in the following cases:
   • the Company obtains data that information about the client, his/her/its representative, related persons or the beneficial owner(s) has changed (e. g. the name, surname or the legal name of the customer has changed, the representative of the customer has changed, the beneficial owner(s) of the customer has changed);
   • a customer updates due diligence information;
   • legal acts establishing sanctions requirements have changed;
   • before each transaction;
   • regularly on ongoing basis.

Risk assessment

1. The Company takes measures to identify, assess, understand and monitor its risks of ML and TF activities and take appropriate measures to mitigate the risks identified.

2. Prior to the launch of a new product or business practice or the use of a new or developing technology, the Company identifies and asses the ML and TF risks that may arise in relation to the development and use of new products or business practices, or new or developing technologies for both new and pre-existing products and take appropriate measures to manage and mitigate those risks.

3. The Company shall document the outcome of the risk assessment and regularly update it.