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As an operating financial company - we actively counteract money laundering and terrorist financing.

AML - Anti-Money Laundering.

AML Act - Act of 1 March 2018 on counteracting money laundering and terrorist financing.

General Inspector of Financial Information - a government administration body with jurisdiction over anti-money laundering matters. It controls compliance with regulations on anti-money laundering and terrorist financing.

Obligated institution - entities obliged to comply with the provisions of the AML Act. These entities are, for example, banks, cooperative savings and credit unions, investment funds, insurance companies, leasing companies, domestic payment institutions, currency exchange offices, real estate agents, entities operating games of chance, parimutuel betting, card games and slot games, auditors and tax advisors, as well as non-profit organisations (foundations, associations) in cases specified in the AML Act.

Politically Exposed Persons - persons who hold politically exposed positions as, inter alia, heads of state, heads of government, ministers, deputy ministers, members of parliament, judges of supreme courts, members of the boards of central banks, ambassadors and who hold or have held these political positions within the time limits set by the AML Act, as well as persons known to be close associates of such persons or their family members.

Money laundering - intentional actions aimed at introducing into the legal market primarily money or other property values obtained from illegal sources or used to finance illicit activities. These activities constitute an offence under Paragraph 299 of the Penal Code.

Financial security measures - measures taken by obliged institutions to mitigate the risk of money laundering and terrorist financing, consisting in particular of identifying the customer and verifying their identity, identifying the beneficial owner, obtaining information on the purpose of the customer's relationship with the obliged entity and ongoing monitoring of the economic relationship with the customer.

Transaction - a legal or factual act upon which a transfer of ownership or possession of property values is effected, or a legal or factual act performed to transfer ownership or possession of property values, e.g. cash or non-cash deposit and withdrawal, purchase and sale of foreign exchange.

Transaction withholding - temporary prevention from disposing and using money, which is the act of averting concluding the transaction by the obligated institution.

Freeze - prevention of moving, changing and using the possessions or concluding transactions in any form that can change the amount, value, location, ownership, character, destination or any other adjustment that can make it possible to use the possessions.

Money laundering and the financing of terrorism is an international issue, counteracted by countries by applying the regulations defined in the national acts. Despite the fact that the national acts might differ, they are unanimous regarding their key objectives. Their primary aim is to prevent offenders from using the financial system of the country.

In Poland, the Act of 1 March 2018 on counteracting money laundering and terrorist financing is the official document. Additionally, the Regulations of the Minister of Finance are executive orders. The Act describes required duties to be fulfilled by the obligated institutions in order to counteract money laundering and terrorism financing. The Regulations indicate the manner of execution.

Within the European Union, countering money laundering and terrorist financing is regulated by Directives and Regulations. Financial institutions operating globally are required to comply not only with national requirements but also with the regulations of the countries in which they provide services.

As a potential customer, during the registration process, personal data is necessary for identification purposes. The submitted data is used to verify the information included in money transfers from the bank, with which you hold your account and with which you will settle your buy / sell currency transactions. In certain cases, for example, when making a transaction including a foreign bank and if you are not a Polish resident, a scan of your identification card/passport may be required. You don't need to worry about the safety of your data - a special effort is made to ensure that they are carefully and efficiently protected from unauthorized access.

If you are already a user, the request for additional information for identity verification may be required at any time, even if it wasn't necessary during registration. Additional transaction clarification may also be requested. This is because of our commitment to monitoring ongoing transactions and assessing risks.

In order to actively prevent money laundering, we use many different forms of protection and control. Know Your Customer Policy is the main security principle that ensures that we know our customers and are able to assess related risks. For this reason, we must identify our users and verify their identity. We also verify sanction list data and establish our user's PEP status’ based on their statements.

All transactions initiated and settled are monitored. When doubts or suspicions about the character of a transaction arise, the transaction will be withheld and a request for further details will be sent. The transaction will only be completed when we are assured that there is no risk of money laundering or any other unlawful actions.

We register every transaction amounting or equalling to 15,000 EUR or higher as suspicious transactions, irrespective of their amount. Linked transactions amounting to less than 15,000 EUR or its equivalent that have been divided into smaller amounts to avoid registration. All registered transactions are sent to the General Inspector of Financial Information.

When a customer’s personal data is found on any sanction list, additional analyses are conducted in order for us to be certain that a business cooperation can be formed. In the case of a confirmed alert on the sanction lists, we will refuse to form a collaboration, and it may be necessary to use the mechanism of freezing property values, or transaction withholding. We are obliged to report such cases to the General Inspector of Financial Information and act accordingly.

During proceedings concerning the suspicion of money laundering or financing of terrorism, prosecutors or the police have the right to request further information, which we are then obligated to provide.

In addition, when we receive information about the criminal character of actions conducted on a customer’s account, the suspicion of committing an offense is reported to prosecutors.

This is due to the financial institutions having an obligation to inform law enforcement about any suspicion of money laundering, fraud or extortion of possessions which could result in our customers becoming victims of a crime. This cooperation between financial institutions and law enforcement significantly contributes to identifying the fraudsters.

Due to the complexity of sanctions imposed by international institutions on specific countries, Conotoxia, using a risk-based approach, has identified the countries listed below as generating unacceptable risks and has decided not to enter into relationships connected with the following countries: Syria, Sudan, Cuba, North Korea, Iran, Burma (Myanmar).