Anti-Money Laundering and Counter-Terrorist Financing Policy

Funds Flow s.r.o. (“we,” “us,” or “our”) has established this Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy to prevent and mitigate the risk of our platform being misused for illicit financial activities. Our goal is to implement stringent internal controls and procedures, fully aligned with international standards and applicable local regulations, ensuring that Funds Flow s.r.o. does not become involved in or facilitate money laundering, terrorist financing, or related criminal conduct.

1. Purpose and Objectives
The financial services industry—particularly digital asset trading platforms—can be targeted by individuals and organizations seeking to conceal illicit funds or channel them for terrorist activities. Our primary objective is to establish a framework that identifies, assesses, and minimizes these risks. This Policy is designed to uphold all relevant laws and regulations while outlining essential responsibilities and processes that support full compliance with AML/CTF requirements.

Money laundering involves disguising the origin of illegally obtained funds to present them as legitimately sourced. Terrorist financing encompasses providing or collecting funds intended to support terrorist acts. By adhering to this Policy, we aim to thwart such activities and uphold the integrity of the financial ecosystem.

2. Risk Assessment and Classifications
2.1 Adopting a Risk-Based Approach
Funds Flow s.r.o. employs a risk-based methodology for AML/CTF compliance. This approach enables us to identify and evaluate the likelihood and potential impact of money laundering and terrorist financing within our services. Based on these assessments, we apply preventive and mitigative measures that are proportionate to the identified risks. Our adaptive strategy ensures that we remain vigilant and responsive to new threats.

2.2 Customer Risk Factors
Assessing customer-related risks is crucial. Certain behaviors or attributes may indicate increased risk—such as inconsistencies in identification documents, the use of aliases, or links to known criminal activity. Moreover, individuals classified as Politically Exposed Persons (PEPs) warrant enhanced scrutiny, as their public functions may expose them to higher risks of corruption or illegal financial dealings.

2.3 Geographical/Country Risk
Transactions involving countries lacking robust regulatory frameworks or known for associations with terrorism or organized crime pose higher risks. When dealing with such jurisdictions, Funds Flow s.r.o. enforces stricter due diligence, including gathering additional information and seeking senior management approval before proceeding with any transaction.

3. Customer Verification and Continuous Monitoring
3.1 Initial Verification
Before granting access to our services, each client must undergo a thorough identity verification process. We collect and verify personal information—such as full name, address, date of birth, and other relevant identifiers—to confidently ascertain a customer’s identity. Enhanced scrutiny may be applied to high-risk customers, potentially extending the verification timeline or requiring additional documentation. We reserve the right to re-verify identities as circumstances change or when suspicious activity arises.

3.2 Ongoing and Retrospective Review
We maintain continuous oversight of our client base and their transaction activities. Real-time and retrospective monitoring methods help us detect unusual, fraudulent, or potentially unlawful conduct. Suspicious transactions are subjected to deeper investigations, and if warranted, we report them to competent authorities without alerting the affected parties. Additional documentation may be requested from customers, and in cases of confirmed wrongdoing, we may suspend or close their accounts.

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4. Roles and Responsibilities
4.1 Compliance Officer
A dedicated Compliance Officer oversees the implementation of this Policy, ensuring that all AML/CTF requirements are diligently followed. This officer is tasked with managing customer verification, risk assessments, and transaction monitoring, and is authorized to initiate internal investigations and submit required regulatory reports.

4.2 Employee Training and Awareness
All Funds Flow s.r.o. personnel receive regular and comprehensive training on AML/CTF policies and procedures. Staff members learn to identify warning signs, handle suspicious transactions appropriately, and swiftly report issues to the Compliance Officer. Our team’s collective awareness forms a key defensive line against illicit financial activities.

5. Reporting Suspicious Activities
In line with legal and regulatory obligations, Funds Flow s.r.o. promptly reports any suspected money laundering or terrorist financing activity to the appropriate authorities—without informing the parties involved. All disclosures are managed with strict confidentiality. We adhere to these reporting requirements to ensure timely intervention by law enforcement agencies and to maintain the integrity of ongoing investigations.

6. Internal Controls and Record-Keeping
To support our AML/CTF efforts, we have established robust internal controls and rigorous record-keeping processes. We meticulously document customer data, transactional histories, and any related investigative findings. These records are securely stored, easily retrievable for regulatory inspections, and maintained in accordance with statutory retention periods. All personal information is handled in compliance with our Privacy Policy and applicable data protection laws, ensuring that sensitive data remains secure and confidential.

7. Regular Policy Review and Updates
Funds Flow s.r.o. regularly reviews and updates this AML/CTF Policy to maintain its relevance and effectiveness. Ongoing assessments enable us to refine our procedures, respond to emerging threats, and incorporate evolving best practices. Amendments may result from regulatory changes, shifts in risk profiles, or lessons learned from internal audits and investigations. All policy revisions are communicated to employees and relevant stakeholders to ensure compliance and operational integrity.

8. Conclusion
This AML/CTF Policy reflects Funds Flow s.r.o.’s unwavering commitment to lawful, ethical, and transparent business conduct. By strictly adhering to these guidelines, we protect our customers, ourselves, and the global financial system from the harmful effects of money laundering and terrorist financing. Our dedicated compliance structure, ongoing training, and rigorous oversight enable us to foster a secure and trustworthy operational environment.

For inquiries or additional details regarding this Policy, please contact our Compliance Officer at moc.liamg%40lagel.wolfsdnuf. We are prepared to clarify any aspects of our AML/CTF measures and to support stakeholders in understanding their responsibilities under this Policy.