KYC & AML Policy (General Information)

For the safety of users and to meet legal requirements in the European Union, the United States of America, and other countries, ALTERNATIVES BROKER SCHWEIZ Ltd. has implemented and applies:

• KYC (Know Your Customer / customer identification)

• AML (anti-money laundering and counter-terrorist financing)

These policies are required from banks and other financial institutions.

The purpose of these measures is to effectively prevent money laundering and terrorist financing through proper identification of account users and supervision of their transactions. We identify and stop transactions carried out not only to buy/sell cryptocurrency, but also those made primarily to conceal the criminal origin of funds, finance illegal activities, or support other unlawful behaviour.

Some specific provisions of our policies are confidential and intended for internal use only to prevent circumvention by dishonest or fraudulent users. Below we present general rules that directly concern you and affect the services we provide.

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User Identification (Individuals)

We are required to verify, beyond reasonable doubt, the identity of persons who can perform transactions on our exchange. This is why we collect:

• scans/photos of identity documents, verified using specialised software by professional external providers.

We may also require:

• a selfie, or

• a photo/video recording with the ID document,
  to prevent the misuse of your documents by someone else.

Verification of your likeness to the ID photo is conducted using specialised software from external providers and, where necessary, may be reviewed manually by our customer support team.

If there are any doubts, our support team will contact you to clarify concerns and resolve issues.

If we cannot determine beyond reasonable doubt that the documents belong to you and are authentic, we will not be able to allow you to execute transactions.

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User Identification (Companies)

For legal entities (companies), verification is more stringent and depends on factors such as the company structure and jurisdiction. In particular, we need to establish:

• who owns the company (beneficial owner)

• who is authorised to represent the company

• where the company is registered and operates

• the nature of the company’s business activities

Because official corporate documentation standards vary across countries, verification for such users is usually performed manually and may be significantly more time-consuming.

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Transaction Monitoring and Supervision

Using proprietary tools, we analyse transactions carried out on our exchange to detect suspicious or unusual activity.

Selected transactions may be reviewed by our AML specialists to determine whether they:

• present no significant AML risk, or

• require suspension and clarification with the User.

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Additional Verification

As your trade volume increases, our AML verification obligations may increase as well. The same applies if:

• your transactions are flagged as suspicious or unusual; or

• our verification indicates you may present a higher AML risk.

In such cases, we may request additional documentation, including proof of:

• place of residence

• education

• occupation / employment

• source of funds used on the exchange

If our AML specialists decide the information received does not sufficiently clarify concerns, we may be required to end our cooperation with you or report transactions to the relevant authorities.

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Basic AML Rules

Our operating rules include, among others:

• ALTERNATIVES BROKER SCHWEIZ does not accept cash deposits or cash withdrawals in any circumstances.

• ALTERNATIVES BROKER SCHWEIZ does not accept third-party deposits to a user’s account and does not allow account management on behalf of someone else, shared accounts, or joint accounts.

• ALTERNATIVES BROKER SCHWEIZ does not allow exceptions regarding documentation required from users.

• ALTERNATIVES BROKER SCHWEIZ reserves the right to refuse to process any transaction at any time if an AML risk is suspected.

• In accordance with international law, we may be not obliged (or may be prohibited) from informing clients if we report suspicious behaviour to relevant authorities.

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Sanctioned and Restricted Countries

In accordance with our policies, we do not open accounts and do not process transactions for citizens or residents of, or persons staying in, countries where transactions are prohibited by international sanctions or internal regulations.

We may also restrict countries that, based on criteria used by our AML team, are assessed as high risk (for example, Transparency International’s Corruption Perceptions Index, FATF warnings, or the European Commission list of jurisdictions with weak AML/CTF regimes).

Currently, these countries include:

Afghanistan, American Samoa, Angola, Bahamas, Botswana, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states).

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Tiers of KYC Verification

As trade volume increases, AML risk typically increases as well. For this reason, we apply appropriate safety and verification procedures.

We use a three-tier verification system, based on the general rule that:

the more funds (or cryptocurrencies) you deposit or wish to withdraw, the more information about you and your funds may be required to exclude AML risks, as required by law.

This model is based on the work and experience of our AML team and may be updated due to:

• changes in legal requirements in different countries

• new knowledge and operational experience

• periodic audits and efficiency reviews

We will keep you informed if any changes may affect your situation.