Anti-Money Laundering and Countering Financing of Terrorism Policy

SYSTEM OF INTERNAL POLICIES (SOP), PROCEDURES AND CONTROL MEASURES

Of OWNR WALLET EUROPE S.R.O., reg no 10665587

Introduction

This System of Internal Policies, Procedures and Control Measures (hereinafter referred to as the "SOP") regulates the activities of the managers and employees of OWNR WALLET EUROPE S.R.O. (hereinafter referred to as "OWNR WALLET") for the purpose of preventing the laundering of proceeds of crime, the financing of terrorism and the application of sanctioning measures. This SOP is prepared in accordance with Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing, as amended (hereinafter referred to as the "AML Act") and the methodological instructions of the Financial Analysis Office (hereinafter referred to as the "FAO").

Definitions

AML/CFT prevention – Measures in the area of prevention of money laundering and financing of terrorism (Anti-Money Laundering / Countering the Financing of Terrorism).

FAO (Financial Analytical Office) - The FAO acts as the financial intelligence unit of the Czech Republic and is part of a global network of financial intelligence units. The activities and powers of the FAO are defined by the AML Act.

Politically exposed persons (PEP) - A natural person who is or has been in a significant public political office of national or regional importance, such as, a head of state, a prime minister, the head of a central government body and other similar politically exposed positions. Persons directly related to such persons are also considered as PEP.

Risk Based Approach is an approach to the implementation of AML/CFT measures that enables OWRN WALLET to allocate resources (human and financial) appropriately while effectively managing ML/TF risks. Effective RBA is based on a carefully conducted risk assessment (to identify, understand and assess risks). This enables Obligated Persons to implement mitigation measures that are appropriate to the risks.

Suspicious transaction A transaction carried out in circumstances giving rise to a suspicion of an attempt to launder the proceeds of crime or a suspicion that the funds used in the transaction are intended to finance terrorism, or that the transaction is otherwise related to or connected with the financing of terrorism, or any other fact that might indicate such a suspicion.

Customer Identification (Customer Due Diligence)

OWNR WALLET performs customer identification as an integral part of our procedure and control measures. This process is comprehensively applied before establishing any business relationships with both individual and corporate customers. The process contains of online KYS verification, PEP/Sanctions checks and other necessary steps. Within the identification process we collect such information as:

• Full name;
• Date of birth;
• Place of birth and constant residence;
• Nationality;
• Occupation;
• Source of funds and wealth;
• Nature of business, business relations (for corporate customers)
• Other information and documents

For customers of high-risk group, the enhanced due diligence process is applied, meaning the collection and processing of additional information and documents

Transaction Monitoring

The Company applies the following transaction monitoring measures in order to detect: • suspicious and unusual transactions and their patterns; • transactions that exceed the prescribed limits; • links to persons of diminished credibility and international sanctions.

OWNR WALLET retains the right to request additional information or supporting documentation for any transaction, and/or decline the provision of services if transactions risk score do not comply to our policies.

Sanctions Screening

A subject of international sanctions is a natural or legal person, institution or other entity that is directly listed in the legislation governing the imposition or implementation of international sanctions and against which the measures referred to in that legislation are taken.

MLRO

An independent unit or employee of OWNR WALLET who is responsible for reviewing compliance with legal requirements, screening employees and individuals working for OWNR WALLET other than in a primary employment relationship, and reviewing the effectiveness of these policies, procedures and communications.

Suspicious Activity Reporting

If we encounter activities that raise suspicion of money laundering or terrorist financing, we commit to immediately fulfill our legal obligations and report to the relevant authorities.

If a judicial or law enforcement agency in a country or region requests assistance during an investigation, the platform reserves the right to cooperate and provide necessary information and materials. This cooperation is carried out in accordance with applicable legal provisions and the requirements of the authorities.

AML Training

We pay attention to providing a comprehensive AML/CTF training program for all employees, supplemented by job-specific instruction. These training sessions are held at least once a year to ensure that all participants are always aware of and comply with the latest laws and regulations. In addition, our employees receive additional training when necessary, such as when new laws or regulations are passed or due to legal requirements.

New employees also receive appropriate training before starting work at the company. Our training programs are regularly updated to meet the latest laws and regulations and ensure that our employees are always fully prepared to meet compliance standards.

Record-Keeping

We keep records of all customer information and transactions in accordance with anti-money laundering laws and regulations. This information will be treated confidentially and will only be passed on to authorized persons and authorities when necessary.

We will retain originals or copies of documents used to identify and verify individuals and documents used to establish the business relationship for at least five years after the end of the business relationship.

We will retain documents related to transactions and documents and data based on reporting obligations on any data medium for at least five years after the completion of the transaction or the fulfillment of the reporting obligation.

Virtual asset/currency

It is an electronically storable or transferable unit that is • capable of performing a payment, exchange or investment function, whether or not it has an issuer, unless it is (i) a security, investment instrument, or monetary instrument pursuant to Act No. 370/2017 Coll., on payment transactions (hereinafter referred to as the "PTA"), (ii) a unit as referred to in Section 3(3)(c)(4) to (7) of the PTA, or (iii) the unit by which the payment is made under Section 3(3)(e) of the PTA, or • a unit referred to in point (a)(ii) and which can ultimately be paid only for a narrowly defined range of goods or services which includes an electronically storable or transferable unit referred to in point (a).

Conclusion

OWNR WALLET EUROPE S.R.O. is committed to preventing money laundering and takes all necessary measures to ensure the effectiveness of our AML program. We continuously update and improve our AML program to adapt to changing regulations and new risks. We appreciate your cooperation in maintaining a safe and compliant environment.

OWNR WALLET EUROPE S.R.O.

Last updated Jul 29, 2024