Anti money laundering (aml) and counter terrorist financing (ctf) Processes Implemented by the Company

The Company introduces and implements its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy in accordance with relevant legal acts, recommendations, guidelines, and best practices in the industry. The Company is committed to providing reputable, reliable, and secure services with high standards of integrity and transparency, in full compliance with applicable laws and global standards.

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The Company’s approach to ML/TF prevention is based on the following core principles:

• The Company will take all reasonable precautions to ensure that its products and services are only utilized for legitimate purposes;
• The Company will avoid relationships with Customers that pose an unacceptable risk of ML/TF as per the Company’s assessment;
• The Company will not tolerate conduct that compromises its compliance with AML/CTF requirements;
• The Company will manage changes to its products, business processes, and systems in a way that ensures effective ML/TF risk management.

CDD is a mandatory due diligence process conducted by the Company to identify its Customers and ascertain relevant information before starting a business relationship. The main purpose of the CDD process is to prevent identity theft, fraud, money laundering, or terrorist financing.

While performing the CDD, the Company conducts the following actions, among others:

• Identifies the Customer and verifies the information obtained during the due diligence process, relying on identity and other documents;
• Establishes whether the Customer is a politically exposed person (PEP);
• Assesses whether there are grounds for enhanced due diligence;
• Verifies whether the Customer is included in any list of persons subject to international financial sanctions or other restrictive measures.

If the Company is unable to comply with relevant CDD requirements, it must not establish a business relationship with the respective Customer. Information, documents, and data provided to the Company during the identification of the Customer are processed in accordance with the Privacy Policy.

The ongoing due diligence process comprises two aspects:

• The obligation to carefully examine transactions carried out over the course of the business relationship with Customers, including monitoring the Customer's occasional transactions and paying attention to suspicious Customer behavior;
• The obligation to update the data or information collected as part of the identification and identity verification process.

Based on the above, the Company implements a transaction monitoring process and conducts periodic reviews for its Customers.

A risk-based approach refers to the assessment of the potential risk of ML/TF posed by the Company's (potential) Customers and the implementation of measures to reduce or mitigate such risk. As a result, the Company shall allocate and prioritize resources according to where the most risk mitigation is required.

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The Company implements internal procedures to carry out individual ML/TF risk assessments and assign Customers (both when entering into and during ongoing business relationships) to risk groups (categories). The Company's Customers will be assigned to risk groups (categories) based on various criteria.

The Company takes measures to ensure compliance with relevant regulations and legislation on sanctions. It is particularly vital that the Company is able to identify sanctioned subjects and transactions violating sanctions, which may arise in the course of its business activities.

The Company takes into account the following sanction regimes:

• United Nations Security Council Sanctions;
• European Union Sanctions;
• Office of Foreign Assets Control Sanctions;
• Republic of Lithuania International Financial Sanctions.