AML DIRECTIVE

of Simple Coin s.r.o.

ID: 01516558, with registered office at Bubenečská 184/1, Dejvice, 160 00 Praha 6,

registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 207798

against money laundering and terrorist financing

I. Definitions

1.  “Directive” means this directive against money laundering and terrorist financing, which is an integral part of the Terms.

2. “Terms and Conditions” are the general terms and conditions that govern our and your rights and obligations in the context of Digital currency trading.

3. “Contract” is an agreement to buy or sell Digital currency at our current exchange rate, which we have entered into with you through our website    https://client.simplecoin.eu/   .

4. “Trade” means purchase and/or sale of Digital Currency realized based on the Contract.

5. “AMLZ” is Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from criminal activities and terrorist financing, as amended.

6. “Authority” means the Financial Analytical Office at Washingtonova 1621/11, 11000 Praha 1.

II. Identification 

1. In compliance with AMLZ, we are obliged to carry out measures against money laundering and terrorist financing. Within this framework, we identify or check our clients in accordance with provisions of the AMLZ.

2. In particular, we will carry out the identification:
   1. if it is evident that the value of the Exchange exceeds the amount of EUR 200 over a period of 10 consecutive days; 
   2. if the nature of a transaction is dubious; or 
   3. in the process of establishing a business relationship. 

3. Exceeding the EUR 200 Limit: In order to assess whether the limit of EUR 200 has been reached, we sum the values of Trades made over a period of ten consecutive days by the respective client or via the relevant e-mail address. 

4. Suspicious transaction: Suspicious transaction is to be understood as referring to a trade that takes place under circumstances that give rise to suspicion of attempts at money laundering; suspicion that the funds used in the trade are intended to finance terrorism, or that the trade is otherwise associated with the terrorist financing; or due to another fact that could suggest such a suspicion. The transaction is considered suspicious whenever the client refuses to submit to inspection as described below.

5. We process the identification as follows:
   1. if you are a natural person, we will record and verify from your identity card:
      1. identification data,
      2. Type and serial number of the identity card, 
      3. the State or the authority which issued it, and 
      4. its period of validity; 

and at the same time we will verify selfie based on your ID match your likeness to the image on the identity card;

2. if you are a legal entity, we will record and verify your identification data from the document proving the existence of the legal entity and also identify the natural person who represents you in the given case; If your statutory body, its member or controlling entity is another legal entity, we will also record its identification data.

6. During the identification process, we verify and record whether you are a politically exposed person or whether they are not a person against whom the Czech Republic applies international sanctions under the Act on the Implementation of International Sanctions.

7. For subsequent Trades, we only verify the identity of natural persons (acting on their own behalf or representing a legal entity).

8. During the term of the Contract or during subsequent Trades, we check the validity and completeness of your identification data.

9. At the place of identification, we may ask you to arrange formal identification by a notary or a public administration contact point, or to take over the identification made by a credit or financial institution in connection with the establishment of a business relationship.

III. Review

1. In particular, we will conduct a Review:
   1. prior to trading that is performed outside a business relationship, no later than when it is evident that the Trade will reach a value of EUR 10,000 or more over a period of 30 consecutive days; 
   2. if the nature of a transaction is dubious; 
   3. in the process of establishing a business relationship; and
   4. for the duration of a business relationship,

2. This Review consists of:
   1. obtaining information on the purpose and intended nature of the transaction or business relationship, 
   2. ascertaining the ownership and management structure of the customer and his beneficial owner, where the client is a legal person, and taking measures to identify and verify the identity of the beneficial owner; 
   3. ongoing monitoring of the business relationship, including reviews of transactions undertaken during the course of that relationship; 
   4. reviewing the sources of funds or other assets involved in the transaction or business relationship.

IV. Common Provisions 

1. Based on the risk assessment, we may change the limits for Identification and Review at any time, or introduce new limits for individual types of Trades.

2. If, based on risk assessment, if the client, business or business relationship represents an increased risk of money laundering or terrorist financing, we perform Escalated Identification and Review of the client within the scope of AMLZ.

V. Client Obligations and Consequences of their Breach

1. It is your responsibility to provide us with the information necessary to carry out Identification and Review, including the submission of relevant documents, and all cooperation necessary to fulfil the obligations arising from the AMLZ. Details regarding the provision of information and documents are regulated in Art. IV. of the Terms of Service.

2. Failure to comply with Identification or Review or failure to provide the necessary cooperation on your part will result in refusal to execute the Trade or termination of the Contract.

3. We are obliged to report Suspicious Transactions without undue delay to the Authority, which will then decide on further measures.

4. In the event of a Suspicious Transaction, the processing of your order may be postponed or your property may be seized, in accordance with the decision of the Authority.

IV. Final Provisions

1. This Directive is an integral part of the Terms and Conditions and we may unilaterally amend or supplement it at any time.

2. By agreeing to the Terms and Conditions, you confirm that you have thoroughly read this Directive, fully understood it, accept it without reservation and will comply with it.