AML & KYC Policy

LiquiTrade Limited (the “Company”) has established an Anti‐Money Laundering and Know Your

Customer Policy (hereinafter ‐ the “AML & KYC Policy”), in an attempt to maintain the best compliance

practices in conjunction with applicable laws and regulations relating to anti‐money laundering in all

countries where we operate.

AML & KYC Policy covers the following areas:

 Internal Controls

 Compliance Officer

 Training

 Customer Verification Procedures

 Monitoring of Transactions

 Customer due diligence

 AML Program Audit

Internal Controls

We have designed a structured system of internal controls in order to comply with applicable AML &

KYC laws and regulations, some of which are outlined in this Policy including, but not limited to, our

Customer Verification Procedures, filling Suspicious Activity Reports (“SARs”), as well as other

requirements and audits.

Compliance Officer

The Compliance Officer is the person, duly authorized by the Company, whose responsibility is to

develop and enforce the effective implementation of the AML & KYC Policy. The Compliance Officer is

required to report any violations of the AML & KYC procedures and is responsible for collecting and filing

SARs.

Training

All employees receive a full AML & KYC training, along with a job‐specific guidance. Training is conducted

at least once a month to ensure that trainees are informed and act in compliance with all applicable

laws and regulations. New employees receive relevant training within thirty (30) days of their start date

and before they could perform any compliance related duties. Training program is updated regularly to

reflect current laws and regulations. Compliance Officer maintains the training logbook, which is

available for verification during the annual third party review.

Customer Verification Procedures

The Company establishes its own customer verification procedures within the standards of AML & KYC

frameworks. In order to open an account, customer’s identity and place of residence need to be verified

and checked against sanctions and watch lists, including the Office of Foreign Assets Control (“OFAC”)

and Politically Exposed Persons list (“PEP”). In addition, certain groups of assets are limited to investors

with “qualified” status only. In order to open an account for an individual customer, the following

information needs to be verified:

 Email address;

 Mobile phone number;

 Full name;

 Date of birth;

 Proof of identity (government identity card, driver’s license, passport);

 Citizenship;

 Proof of residential address (utility bills, bank statement, official government letter); and

 Additional information or documentation if requested.

Based on the information collected during the KYC process the Company have a right, at its own

discretion, to restricts or refuse service to a particular client.

Monitoring of Transactions

The Company uses customer transaction monitoring as a risk‐assessment and suspicious activity

detection tool. If a transaction is inconsistent with a customer’s known personal activities or personal

habits, this transaction may be considered suspicious. Data and transaction monitoring tools are used to

identify uncommon patterns of customer’s activity. After review and investigation, it is Compliance

Officer’s decision whether to file a SAR or not.

Once a SAR is filed with a relevant agency, a copy of filing documentation is maintained onsite. SAR filing

is confidential and only the Company’s employees involved in the investigation and reporting process

will be aware of its existence.

All records are retained for eight (8) years and are available upon official request by an authorized

examiner, regulator, or law enforcement agency.

Customer Due Diligence

The Company use risk based approach to select a sample of its clients for an additional verification.

We use proprietary risk assignment algorithms to reflect many aspects of customer characteristics and

behavior, including but not limited to:

 account balances;

 value and pattern of transactions;

 consistency of data provided during customer verification process;

 unusual behavior

 history of devices and IP addresses used to enter the site;

 origin and destination of external transfers

 etc.

Sample of clients identified as high risk ones and a strata of stochastically selected clients are regulary

submitted for extended due diligence. Such due diligence involves:

 verification of identity documents’ validity with issuing authorities

 verification of facial similarity of photo and that in the documents

 Verification of supporting documents though independent checks

 checks of selected data against watchlists

AML Program Audit

The Compliance Officer is responsible for conducting AML & KYC review on periodic basis.

In addition, annual independent test of the AML & KYC procedures is done by a qualified third party. In

order to achieve segregation of duties, the Compliance Officer is not involved in such independent test.