Anti-Money Laundering Policy (AML)

Last updated: April 17, 2024

DB ZION ALPHA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (KRS: 0001043322, Virtual Currency Activities Register: RDWW-8221)

Definition and Purpose

Money laundering involves converting illegally obtained funds (from terrorism, corruption, drug dealing, etc.) into legal investments while concealing their criminal origin. Governments combat this activity to prevent criminal funds from entering the economy.

Financial institutions, particularly digital currency services, are vulnerable to exploitation by criminal organizations. Zion company actively participates in preventing such activities globally.

Company Actions and Measures

Zion implements the following procedures:

Verification of client identity and personal information with monitoring of all customer transactions
Tracing suspicious operations and those conducted under irregular circumstances
Right to request additional verification or cancel transactions at any stage if illegal activity or money laundering is suspected
Under international law, no obligation to notify customers of suspected criminal activity
Actions based on AML FATF references

The company regularly updates its electronic systems per new regulations and conducts staff training to improve anti-money laundering methods.

Risk Assessment Framework

Default Risk Status: All clients default to low risk unless risk factors are present.

Automatic High-Risk Characteristics

Politically exposed persons
Clients with filed suspicious transaction or terrorist financing reports
Identified terrorists
Clients where beneficial ownership information cannot be obtained
Clients from high-risk countries

Risk Indicators

Client Characteristics, Product, Service and Delivery Channel

Politically exposed persons, heads of international organizations, and close associates
Unknown source of funds
Large transaction orders from/to high-risk foreign jurisdictions
Third-party involvement without reasonable justification
High-risk occupations: cash-intensive businesses, offshore operations, high-risk country businesses, online gambling
Unusually complex business structures or transactions
Non-face-to-face identification without justifiable reason

Geographic Indicators

Client residence outside local or normal client area
Residence in known crime areas
Offshore business activities or connections to high-risk countries

Suspicious Transaction Indicators

Transaction volume, timing, or complexity inconsistent with client's personal/business activity or account purpose
Deposit/transfer values inconsistent with occupation or stated source of funds
Presence of other suspicious transaction indicators outlined in background information

General Indicators of Suspicious Activity

Client admits to or makes statements about criminal involvement
Refusal or avoidance of providing required information; providing misleading, vague, or unverifiable information
Production of seemingly false, counterfeited, altered, or inaccurate documentation
Accounts with multiple financial institutions in one area without apparent reason
Repeated use of an address with frequent name changes
Uncommon curiosity about internal controls and systems
Confusing transaction details or limited knowledge of transaction purpose
Familiarity with money laundering or terrorist financing issues
Refusal to produce personal identification documents
Frequent travel to high-risk countries

Industry-Specific Examples

Requests for foreign exchange rates exceeding posted rates
Willingness to pay transaction fees above posted amounts
Currency exchange with requests for largest denomination bills
Limited knowledge of payee details; reluctance to disclose or requests for bearer instruments
Requesting replacement cheques in same currency
Cash conversion to cheques outside normal business practice
Cash exchange for numerous small-amount postal money orders for multiple parties
Transactions with unusual counterparties
Third-party fund pickup instructions
Large traveler's cheque purchases inconsistent with known travel plans
Large-volume money order purchases

Restricted Activities and Client Categories

Website refuses account opening and services to clients with unacceptable risk levels.

Private Individuals

Refusal applies to those with:

Negative personal/business information from trusted sources indicating relation to crime proceeds, laundering, or terrorism (World Check, public authorities)
Previously frozen or arrested funds related to suspected criminal activity
Attempts to avoid information provision or hide economic activity
Involvement in: arms/ammunition trafficking, unlicensed forex/binary options, escort services, pornographic distribution, cash collection, debt recovery, drug/supplement distribution, detective services, direct marketing, pyramid schemes, telemarketing, pawnshop services, auctions, tobacco/alcohol distribution
Economic activity requiring legal entity registration
Complex, unusually large, or unclear transactions regarding legal/economic objectives

Legal Entities

Refusal applies to organizations involved in:

Information avoidance or economic activity concealment
Negative information from trusted sources indicating crime relation
Previously frozen funds
Improperly licensed reinsurance services
Arms/ammunition trafficking
Unlicensed investment services in non-EEA jurisdictions
Shell company status
Unlicensed gambling services
Unclear establishment reasons with vague objectives
Unlicensed forex/binary options services
Complex or unclear transactions
Activities listed under private individuals section

Risk Categories and Due Diligence

Clients fall into two categories: low-risk and high-risk. Enhanced Due Diligence (EDD) is performed for high-risk clients.

High-Risk Client Definition

Politically exposed persons, family members, or close associates
Individuals with known prior criminal records

Sanctions Compliance

Website is prohibited from transacting with individuals, companies, and countries on prescribed sanctions lists and screens against:

United States Office of Foreign Assets Control (OFAC) lists
Canadian Government Sanctions Lists
United Nations Security Council Sanctions List
Consolidated List of European Union Financial Sanctions
List of Specially Designated Nationals and Blocked Persons
Other applicable sanctions lists

Particular attention is paid to entities from non-cooperative countries and territories identified by the Financial Action Task Force (FATF).

Non-Serviced Countries

Website does not open accounts or provide services to clients from: Afghanistan, Angola, Bosnia and Herzegovina, Botswana, The Bahamas, Cambodia, Burundi, Democratic Republic of the Congo, Central African Republic, Republic of the Congo, Algeria, Ecuador, Eritrea, Ethiopia, Ghana, Guinea, Guinea-Bissau, Guyana, Haiti, Iraq, Iran, Japan, Kenya, North Korea, Lebanon, Liberia, Libya, Myanmar, Nigeria, Pakistan, Serbia, Russian Federation, Sudan, Sri Lanka, Somalia, South Sudan, Syria, Tunisia, Trinidad and Tobago, Uganda, United States, Vanuatu, Venezuela, Yemen, Zimbabwe.

Ongoing Monitoring and Customer Obligations

Website's AML policy includes customer and beneficial owner due diligence with ongoing monitoring and reporting. Website may request transaction information at various times and reserves the right to reject payments if customers don't respond sufficiently or timely per applicable AML laws and regulations.

Multiple Accounts Policy

Customers may not maintain more than one account
Detection of multiple accounts results in temporary disablement of all accounts
Customer must select one active account; others remain permanently blocked
Creating multiple accounts to overcome payment limits triggers additional verification requests
Non-compliance results in refund to original sender while retaining applicable transaction fees

Required and Supported Documents

Identity Verification

Government-issued International Passport
Government-issued Identity Card
Government-issued Driving License
Selfie with Identity Document

Address Verification

Utility bill or bank statement not older than 6 months
Paper or electronic versions accepted
No document modifications allowed

Additional Verification Documents

Credit card photo (specific cases only)
Selfie with credit card (specific cases only)
Photo with printed or handwritten declaration (high-amount cases)

Document Quality Requirements

All documents must be high quality with readable text, no modifications or edits. Poor quality submissions will be rejected and new copies requested.