AML POLICY

UAB A-Pex Exchange is a legal entity, incorporated under the laws of Lithuania, having its registered office at Lithuania, Vilnius, Eisiskiu Sodu, 18-oji Str. 11, (hereinafter also as “us”, “we” and in case of relation to us – “our”) which provides Services through www.coingira.com (the Website) and/or mobile application (collectively or individually “The Platform”).

1. Purpose of AML Policy
   
   

At UAB A-Pex Exchange, we are obligated to comply with anti-money laundering (AML) requirements to prevent financial crimes. Our team is dedicated to upholding the highest standards of AML and Know Your Customer (KYC) compliance to reduce the risk of our services being used for illicit activities. To ensure the safety of our services, we have established an AML Policy that adheres to Lithuania’s AML laws, EU regulations, and international AML guidelines.

2. Definition of AML Policy
   
   

Our AML Policy is a set of procedures designed to prevent and prohibit money laundering and any activities that support it or fund terrorist or criminal operations, while complying with all applicable requirements. KYC measures are integrated into our AML Policy, as they enable us to understand our customers better and manage our risks. We regularly review and update our AML policies, procedures, and internal controls to ensure compliance with applicable European and International regulations and changes in our business.

If we notice any suspicious or unusual transactions or customer behavior, we take appropriate measures to address the risks. Our transaction-handling staff may request additional documents, such as proof of the source of funds, as needed. We keep a well-organized record-keeping procedure, including customer identification documents and related data, in accordance with personal data protection laws. All customer and transactional information is kept confidentially.

Our AML policy includes:

• Developing strong internal policies, procedures, and controls to combat any attempt to use our services for illegal or illicit purposes, and ensuring that our customers are protected under consumer protection laws.

• Appointing an AML/CFT Compliance Officer to oversee our AML/CFT procedures.

• Conducting an internal and independent audit of our AML/CFT policies annually.

• Verifying the identity of customers before establishing a financial relationship with us.

• Establishing and maintaining risk-based customer due diligence, including enhanced due diligence for customers presenting higher risks.

• Monitoring customer financial behavior through transaction analysis based on risk assessment.

• Establishing internal procedures for reporting suspicious activity to relevant law enforcement authorities.

• Providing regular AML training for our staff.

We are required to reject customer documents, close accounts, and terminate the business relationship if we identify any suspicious activity, false documents, or lack of cooperation during the customer due diligence process.

4. Sanctioned countries

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In accordance with our policies, we are required to increase our AML/CTF verification measures when your trade volume rises or if your transactions are flagged as suspicious or unusual. Additionally, if our verification process determines that you pose a significant AML/CTF risk, we may not be able to open an account or process transactions for you. Furthermore, we do not process transactions for individuals who are citizens, residents or staying in countries where transactions are prohibited by international sanctions or internal law regulations. We may also prohibit transactions to individuals in countries that our AML team has determined to be high-risk based on various criteria such as the Corruption Perceptions Index by Transparency International, FATF warnings, and countries with weak anti-money laundering and terrorist financing regimes determined by the European Commission.

At present, the countries considered to fall under these criteria are

Afghanistan, Albania, Algeria, Bahamas, Barbados, Belarus, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands, Central African Republic, China, Congo, Cuba, Democratic Republic of Congo, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Israel, Jamaica, Japan,Jordan, Kyrgyztan, Lebanon, Libya, Mali, Malta, Maynmar, Morocco, Mozambique,Niger, Nigeria, Nicaragua, Pakistan, Palestine Territory, Panama, Philippines, Puerto Rico, Russia, Senegal, Serbia, Somalia, South Sudan, Sudan, SaudiArabia, Syria, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, Uzbekistan, United States, Venezuela, Virgin Islands U.S., Yemen, Zimbabwe.