AML/CTF Policy

The purposes of the Podnarost s.r.o., Registered address: Vlkova 532/8, Žižkov, 130 00 Praha 3, Czech Republic, Registration Number: 19235445, support@podnarost.com Anti-Money Laundering and Counter-Terrorist Financing is to identify, prevent and mitigate possible risks of Podnarost s.r.o. being involved in illegal activity.

Financial institutions and related entities (including cryptocurrency exchanges) are frequently exposed to attempts of money laundering and terrorist financing. Anti-money laundering (AML) refers to a system of laws, regulations, and procedures designed to prevent criminals from presenting illegally obtained funds as legitimate income. Terrorist financing involves providing support to individuals or groups engaged in terrorism. Even in the absence of direct funding, activities such as fundraising, use, possession, or arrangement of funds are also considered forms of terrorist financing.

Podnarost s.r.o. pays close attention to any activities that may be associated with money laundering or terrorist financing. In order to comply with both international and local regulatory requirements, Podnarost s.r.o. has established effective internal procedures aimed at preventing money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery, as well as taking appropriate action in response to any suspicious activity from its clients.

The key measures include:

Customer verification procedures
Risk assessment
Risk categorization
Monitoring of customer activity
Reporting suspicious activities to the relevant authorities

Podnarost s.r.o. has appointed a Compliance Officer responsible for the implementation of the company’s AML policy, including, but not limited to, the activities described below.

Verification Procedure

Before a customer can access and use the services of Podnarost s.r.o., their identity must be verified. This requirement is essential to combat money laundering and terrorist financing. Applicable laws require financial institutions to collect, verify, and maintain information that identifies each individual or entity wishing to engage in business. Customers are required to provide their name, address, date of birth, and other relevant information about themselves or their organization to enable proper identification before any business relationship is established.

Customers who are considered higher risk by Podnarost s.r.o. may be subject to enhanced due diligence. This may involve requesting additional documentation and extending the verification period.

Podnarost s.r.o. reserves the right to conduct ongoing identity verification, particularly if a customer’s identification details change or if their activity appears unusual or suspicious. The company may also request updated documents even if they were previously verified.

Customer identification data is collected, stored, processed, and protected in strict accordance with Podnarost s.r.o.’s Privacy Policy and applicable regulations.

Risk Assessment

To meet its obligations under AML and Counter-Terrorist Financing (CTF) regulations, Podnarost s.r.o. applies a risk-based approach. This approach allows the company to identify, evaluate, and understand the risks of money laundering and terrorist financing it may face, and to implement appropriate mitigation measures based on the level of risk.

Risk Categories

1. Customer Risk:
This includes, but is not limited to, suspicious indicators such as inconsistencies in identification documents, fictitious identities, stolen or forged documents, use of a post box address, prior involvement in financial crime, links to terrorism, being a wanted individual, lack of valid contact information, invalid documentation, or inconsistencies in documents provided by legal entities.

Politically Exposed Persons (PEPs):
These include individuals holding prominent public positions, such as heads of state or government, ministers and their deputies, members of parliament, political party officials, judges of supreme courts, members of central bank boards, ambassadors, high-ranking military officers, senior executives of state-owned enterprises, and key officials in international organizations (excluding mid- or lower-level staff).

2. Country Risk:
In accordance with AML directives, enhanced due diligence is required for transactions or business relationships involving high-risk jurisdictions. This includes obtaining additional information about the customer and beneficial owner, the source of funds and wealth, the purpose of transactions, and securing approval from senior management before establishing or continuing such relationships.

Monitoring of Customer Activity

Podnarost s.r.o. conducts continuous and retrospective monitoring of customer activity to detect any fraudulent, illegal, or suspicious behavior. All transactions are subject to review. Any suspicious activity is thoroughly investigated and, where necessary, reported to the appropriate authorities or addressed through restrictive measures to prevent money laundering or terrorist financing.

In cases of suspicious transactions, Podnarost s.r.o. may request additional information or documentation from the customer. The company reserves the right to suspend or terminate its relationship with a client if there is reasonable suspicion of involvement in illegal activities.

Reporting Suspicious Activities

In accordance with its AML policy and applicable legal requirements, Podnarost s.r.o. will report any activities suspected of involving money laundering or terrorist financing to the relevant authorities when necessary. The company will not disclose the existence of such reports and will not respond to inquiries related to them.