Finzero AML POLICY

Having regard for the safety of the users and due to the legal requirements, The European Union, The United States of America and other countries, Finzero UAB has implemented and started to use KYC policy (customer’s identification), AML / CTF (combating money-laundering and terrorist financing) as it is required from banks and other financial institutions. The purpose of those policies is an effective combating of money-laundering and terrorist financing (AML / CTF) in our company by proper identification of actual users of our accounts and supervision of their transactions. We shall identify and cease transactions made not only to purchase/sell a cryptocurrency but made mainly to hide the criminal origin of money, finance illegal activity or other unlawful behaviors. Specific provisions of our policies are confidential and for internal use only, in order to prevent their avoidance by dishonest or fraudulent users. We would like to introduce to you some of the general rules and stipulations of our policies which directly concern you and affect the services we render. User’s identification In the first place, we are obliged to identify, beyond a reasonable doubt, the identity of persons enabled to do transactions. This is the reason why we collect ID scans, which authenticity is verified with special software of professional external providers. We require sending “selfie” or your recording with ID document in order to preclude the possibility of using your documents by someone else. Verification of your likeness to the photo from your ID is made with the use of special software of professional external providers or, in case of doubts, done manually by our customer support services. In case of any doubts, our customer support team will contact you to explain any concerns and solve the issues that arose. If we cannot determine, beyond a reasonable doubt, that the documents you provided belong to you and are the authentic we won’t be able to let you execute any transactions. User’s identification – Companies  In case of all legal entities (companies), the procedure is more stringent and depends on the company’s structure, country, etc. Primarily, we need to establish who is the owner of the company, who can represent it, where the company is based and what is the business of the company. Since standards regarding governmental documentation of legal entities are different in each country, every time the verification of such users is doing “manually” and is considerably more time-consuming. Transactions’ monitoring and supervision  Using our proprietary software we also analyse all transactions that take place in our company looking for suspicious and unusual behaviours. Such selected transactions are analysed by our AML specialists and evaluated if they do not provide significant AML / CTF risks or if they needed to be ceased and clarified with the User. Additional verification  When your trade volume rises, our AML / CTF verification duties increase as well. The same happens when your transactions are “flagged” as suspicious or unusual, or our verification of your personal results in qualifying you as a person imposing significant AML / CTF risk. In such cases, we can require additional documentation proving your real, exact place of residence, education, occupation, as well as the source of money you are using for trading.   Basic AM / CTF Rules   Our operating rules include inter alia as follows: 1. Finzero UAB does not accept cash deposits or cash withdrawals in any cases. 2. Finzero UAB does not accept any third parties’ deposits on the user’s account, managing the account on behalf of somebody, joint or shared accounts, etc. 3. Finzero UAB does not allow any exceptions in the field of documentation required from users. 4. Finzero UAB reserves the right to refuse to process the User’s transaction at any time, in case of suspicion of AML/CTF risk. In accordance with the international law, we are not obliged (or even forbidden) to inform our clients, if we report their behaviours as suspicious to relevant authorities.   Sanctioned countries  In accordance with our policies we do not open accounts and do not process transactions for citizens and residents of, as well as people staying in, countries where transactions are prohibited by international sanctions or their internal law regulations, or countries which based on various criteria selected by our AML team (for example Corruption Perceptions Index by Transparency International, FATF warnings, countries with weak anti-money laundering and terrorist financing regimes determined by European Commission) impose high AML / CTF high risk. Currently, these countries are:Afghanistan, American Samoa, Angola, Bahamas, Belarus, Botswana, Burundi, Cambodia, Crimea, Sewastopol, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Donetsk People Republic, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Luhansk People Republic, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Russian Federation, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states).