AML Policy

Updated 15/07/2025

Extract from the Internal Anti-Money Laundering and Counter-Terrorist Financing Procedure RVFINGROUP sp. z o.o. (Poland) Board Resolution No. AML1-24 dated 25 July 2024 Version: 2.0

This is a public extract from the internal AML/CFT policy of RVFINGROUP sp. z o.o., a licensed Virtual Asset Service Provider (VASP) registered in Poland. The purpose of this extract is to inform clients, partners, regulators, and app store operators of the company’s core anti-money laundering principles and responsibilities.

1. Scope of Application

This AML/CFT policy applies to all employees and contractors of RVFINGROUP sp. z o.o. and governs services related to:

• Exchange between virtual currencies and fiat currencies,

• Exchange between virtual currencies,

• Custodial wallet services,

• Client identity verification and transaction monitoring.

2. Risk-Based Approach

RVFINGROUP applies a risk-based approach to all clients and transactions, categorizing them into reduced, normal, increased, or unacceptable risk levels. Enhanced due diligence (EDD) measures are applied to clients from high-risk jurisdictions, PEPs (Politically Exposed Persons), and unusual transaction patterns.

3. KYC and Identity Verification

Prior to entering into a business relationship, all clients are subject to mandatory Know-Your-Customer (KYC) procedures, including:

• Verification of identity documents,

• Identification of the beneficial owner (UBO),

• Source of funds check (when applicable),

• Sanctions and PEP screening.

4. Ongoing Monitoring

RVFINGROUP continuously monitors:

• Client profiles,

• Transaction activity and frequency,

• Geographic exposure,

• Consistency with expected behavior.

Suspicious transactions are reported to the Polish General Inspector of Financial Information (GIIF) in accordance with the Polish AML Act of 1 March 2018.

5. Prohibited Activities

RVFINGROUP does not:

• Serve anonymous clients,

• Accept or disburse cash,

• Provide services to sanctioned individuals or entities,

• Maintain relationships with residents or entities from restricted jurisdictions (e.g., Russia or Belarus), as per EU sanctions.

6. AML Governance

Responsibility for AML compliance lies with:

• A designated Member of the Management Board,

• An appointed AML Analyst, who supervises compliance, reporting, audits, and training,

• Internal escalation and reporting procedures to the GIIF and law enforcement.

7. Reporting Obligations

• Transactions above €15,000 are reported as threshold transactions,

• Suspicious activity is reported within 2 business days,

• Ongoing statistical reports are submitted quarterly to the GIIF.

Disclaimer

This is a simplified public extract of RVFINGROUP’s full internal AML Procedure. The complete policy includes detailed instructions and technical annexes and is not published online for operational security and regulatory confidentiality reasons.

For further information Registered Office: RVFINGROUP sp. z o.o., ul. Bartycka 22B, Unit 21A, 00-716 Warsaw, Poland VASP Registration No.: RDWW-1428