AML/KYC Policy
Last update: April 2025
Introduction
CARPATHIAN FORGE Anti-Money Laundering and Know YourCustomer Policy (hereinafter - the “AML/KYC Policy”) is designated to preventand mitigate possible risks of CARPATHIAN FORGE being involved in any kind ofillegal activity.
Both international and local regulations require CARPATHIANFORGE to implement effective internal procedures and mechanisms to preventmoney laundering, terrorist financing, drug and human trafficking,proliferation of weapons of mass destruction, corruption and bribery and totake action in case of any form of suspicious activity from its Users.
AML/KYC Policy covers the following matters:
- Verification procedures.
- Sanctions and PEP lists screening.
- Compliance Officer.
- Monitoring Transactions.
- Risk Assessment.
1. Verification procedures
One of the international standards for preventing illegalactivity is customer due diligence (“CDD”). According to CDD, CARPATHIAN FORGEestablishes its own verification procedures within the standards of anti-moneylaundering and “Know Your Customer” frameworks.
1.1. Identity verification
CARPATHIAN FORGE’s identity verification procedure requiresthe User to provide CARPATHIAN FORGE with reliable, independent sourcedocuments, data or information (e.g., national ID, international passport, bankstatement, utility bill). For such purposes CARPATHIAN FORGE reserves the rightto collect User’s identification information for the AML/KYC Policy purposes.
CARPATHIAN FORGE will take steps to confirm the authenticityof documents and information provided by the Users. All legal methods fordouble-checking identification information will be used and CARPATHIAN FORGEreserves the right to investigate certain Users who have been determined to berisky or suspicious.
CARPATHIAN FORGE reserves the right to verify User’sidentity in an on-going basis, especially when their identification informationhas been changed or their activity seemed to be suspicious (unusual for theparticular User). In addition, CARPATHIAN FORGE reserves the right to requestup-to-date documents from the Users, even though they have passed identityverification in the past.
User’s identification information will be collected, stored,shared and protected strictly in accordance with the CARPATHIAN FORGE’s Privacy Policy and related regulations.
Once the User’s identity has been verified, CARPATHIAN FORGEis able to remove itself from potential legal liability in a situation whereits Services are used to conduct illegal activity.
1.2. Card verification
The Users who are intended to use payment cards inconnection with the CARPATHIAN FORGE’s Services have to pass card verificationin accordance with instructions available on the CARPATHIAN FORGE’s Site.
2. Sanctions and PEP lists screening.
CARPATHIAN FORGE screens applicants against recognisedSanctions and Politically Exposed Persons (PEPs) lists. Individuals and legalentities are screened against mentioned lists:
- on the onboarding stage when the user is submitting the application;
- on each anti-fraud and AML alerts manually by Compliance Officer;
- monthly by running automatically with a script to re-check all DB of customers.
For the screening process performing CARPATHIAN FORGE usesthird-party technology supported by SEPA Cyber Technologies.
3. Compliance Officer
The Compliance Officer is the person, duly authorized by CARPATHIANFORGE, whose duty is to ensure the effective implementation and enforcement ofthe AML/KYC Policy. It is the Compliance Officer’s responsibility to superviseall aspects of CARPATHIAN FORGE’s anti-money laundering and counter-terroristfinancing, including but not limited to:
a. Collecting Users’ identification information.
b. Establishing and updating internal policies andprocedures for the completion, review, submission and retention of all reportsand records required under the applicable laws and regulations.
c. Monitoring transactions and investigating any significantdeviations from normal activity.
d. Implementing a records management system for appropriatestorage and retrieval of documents, files, forms and logs.
e. Updating risk assessment regularly.
f. Providing law enforcement with information as requiredunder the applicable laws and regulations.
The Compliance Officer is entitled to interact with lawenforcement, which are involved in prevention of money laundering, terroristfinancing and other illegal activity.
4. Monitoring Transactions
The Users are known not only by verifying their identity(who they are) but, more importantly, by analyzing their transactional patterns(what they do). Therefore, CARPATHIAN FORGE relies on data analysis as arisk-assessment and suspicion detection tool. CARPATHIAN FORGE performs avariety of compliance-related tasks, including capturing data, filtering,record-keeping, investigation management, and reporting. System functionalitiesinclude:
1) Daily check of Users against recognized “black lists”(e.g. OFAC), aggregating transfers by multiple data points, placing Users onwatch and service denial lists, opening cases for investigation where needed,sending internal communications and filling out statutory reports, ifapplicable;
2) Case and document management.
With regard to the AML/KYC Policy, CARPATHIAN FORGE willmonitor all transactions and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when CARPATHIAN FORGE has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officerwill monitor Users’ transactions on a day-to-day basis in order to definewhether such transactions are to be reported and treated as suspicious or areto be treated as bonafide.
5. Risk Assessment
CARPATHIAN FORGE, in line with the internationalrequirements, has adopted a risk-based approach to combating money launderingand terrorist financing. By adopting a risk-based approach, CARPATHIAN FORGE isable to ensure that measures to prevent or mitigate money laundering andterrorist financing are commensurate to the identified risks. This will allowresources to be allocated in the most efficient ways. The principle is thatresources should be directed in accordance with priorities so that the greatestrisks receive the highest attention.
