Preventing Money Laundering

Ensuring transparency and preventing money laundering and other illegal activities in connection with our services.

All companies in the Crediterium group and its subsidiaries (collectively “Us”, “We” or similar term) follow this Anti-Money Laundering and Know Your Customer Policy (hereinafter the “AML/KYC Policy”), designated to prevent and mitigate possible risks of Us being involved in any kind of illegal activity. Our companies are always required to publish this policy in a conspicuous location in their websites.

Both international and local regulations require Us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in case of any form of suspicious activity from its Users.

Our AML/KYC Policy covers the following matters:

• Verification procedures
• Sanctions and PEP lists screening
• Compliance Officer
• Monitoring Transactions
• Risk Assessment

Verification Procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, We establish Our own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.

Identity Verification

Our identity verification procedure requires the User to provide Us with reliable, independent source documents, data, or information—e.g.: national ID, international passport, bank statement, utility bill. For such purposes, We reserve the right to collect the User’s identification information for the AML/KYC Policy purposes.

We will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and We reserve the right to investigate certain Users who have been determined to be risky or suspicious.

We reserve the right to verify the User’s identity in an ongoing basis, especially when their identification information has been changed or their activity seemed to be suspicious—i.e.:unusual for the particular User. In addition, We reserve the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

User’s identification information will be collected, stored, shared, and protected strictly in accordance with the Our Privacy Policy and related regulations.

Card Verification

The Users who are intended to use payment cards in connection with Our services have to pass card verification in accordance with instructions available on Our site or other collateral material, including our own internal documentation and procedures.

Sanctions and Politically Exposed Persons Lists Screening

We screen applicants against recognized Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:

• On the onboarding stage when the user is submitting the application
• On each anti-fraud and AML alerts manually by Compliance Officer
• Monthly, by automatically re-checking all current customers

For the screening process we may use a combination of information in the public domain as well as information provided by the User.

Compliance Officer

The Compliance Officer is the person, duly authorized by Us, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Our anti-money laundering and counter-terrorist financing, including but not limited to:

• Collecting User’s identification information in a manner consistent with all applicable federal and state regulations
• Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records required under the applicable laws and regulations
• Monitoring transactions and investigating any significant deviations from normal activity
• Implementing a record management system for appropriate storage and retrieval of documents, files, forms, and logs
• Updating risk assessment regularly
• Providing law enforcement with information as required under the applicable laws and regulations

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing, and other illegal activity.

Monitoring Transactions

The Users are known not only by verifying their identity—who they are—but, more importantly, by analyzing their transactional patterns—what they do. Therefore, We rely on data analysis as a risk assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. The monitoring process includes the following:

• Periodic checking of Users against recognized “blacklists”—e.g.: OFAC— aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications, and filling out statutory reports, if applicable.

• We will monitor all transaction and We reserve the right to: (a) Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; (b) Request the User to provide any additional information and documents in case of suspicious transaction; and, (c)Suspend or terminate the User’s account when We have reasonable suspicion that such User engaged in illegal activity

The above list is not exhaustive and the Compliance Officer will monitor the User’s transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

Risk Assessment

We have adopted a risk-based approach to combating money laundering and terrorism financing which is in line with applicable international requirements. By adopting a risk-based approach, We are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most effective ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.