The purpose of this Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CFT") Policy is to ensure that UAB Manimama Exchange ("Company") has internal guidelines to prevent the use of its business for Money Laundering and Terrorist Financing.
This is an abbreviated version of the Policy provided for the convenience of our Customers. The full version of the Policy is available upon your request - email support@manimama.eu.

1. OUR SERVICES

The Company's main economic activity is the Virtual Currency services. For this reason, the Company offers to their Customers the following transaction types:

• providing Custodian Virtual Currency Wallet operator service, which allows to the Customer open Custodian Virtual Currency Wallet on the Customer's name and make transactions with this wallet: to deposit Virtual Currency and to withdraw deposited Virtual Currency to another wallet(s);
  
• providing Virtual Currency exchange operator service, which allows the Customer to exchange, purchase and sell Virtual Currency.
  

All definitions in this Policy are used within the meaning of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing ("Law") (if it is not stated otherwise).

2. CUSTOMER DUE DILIGENCE ("СDD") MEASURES. VERIFICATION PROCEDURES

The CDD measures are taken and performed to the extent necessary considering the Customer's risk profile and other circumstances in the following cases:

• upon establishment of the Business Relationship and during the ongoing monitoring of the Business Relationship;
  
• upon executing or mediating of Occasional Transaction(s) outside the Business Relationship, where the value of the transaction(s) amounts to 1 000 euros or more (or an equal amount in another asset) within 24 hours;
  
• upon verification of information gathered while applying due diligence measures or in the case of doubts as to the sufficiency or truthfulness of the documents or data gathered earlier while updating the relevant data;
  
• upon suspicion of Money Laundering or Terrorist Financing, regardless of any derogations, exceptions, or limits provided for in this Policy and applicable legislation.
• The Company does not establish or maintain the Business Relationship and does not perform the transaction if:

• the Company is not able to take and perform any of the required CDD measures;
  
• the Company has any suspicions that the Company's services or the transaction will be used for Money Laundering or Terrorist Financing;
  
• the risk level of the Customer or of the transaction does not comply with the Company's risk appetite.
  

The Law requires all obligated entities (virtual currency exchange and custodian virtual currency wallet operators included) to obtain, verify and record information that identifies each person or entity ("Customer") who would like to establish Business Relationships or to execute Occasional Transaction with the (obliged entity) Company.
A person seeking to form a Business Relationship, or carry out an Occasional Transaction with the Company is called an Applicant for Business Relationship (or an "Applicant").

Verification procedure is conducted by the Internal Compliance Officer manually. The Internal Compliance Officer must identify and assess these risks, associated with Company's business activity, specific features and scope of the risks, and manage these risks by way of his/her ordinary activities, primarily by way of application of due diligence measures. The Management Board of the Company appoints an Internal Control Officer and Money Laundering Reporting Officer ("MLRO"), who are different persons with relevant competence and knowledge sufficient to perform functions related to their positions.

We are required by Law to ask Applicants to provide the following information:

• For the natural person:
  
  • contact data and identification data: name(s) and surname(s); date of birth; personal number; citizenship; email; phone number; full permanent address (street, house number, postcode/zip code, city, country);
    
  • employment status (employed, unemployed, retired); in case the person employed - full legal name of employer, title/position, nature of business, employer address (street, house number, postcode/zip code, city, country), employer website;
    
  • source of funds: income from salary (detailed description), investment Income (detailed description), retirement income (detailed description), other (inheritance, gift/donation, scholarship, savings/deposits, divorce settlement, government grants, the company profit/dividends);
    
  • bank data: bank account holder name, bank account number (IBAN), bank name, bank SWIFT; and
    
  • the Applicant needs to submit identity documents, which prove information stated above: proof of address (utility bill, redacted bank statement, phone bill, lease agreement) - this document must be not older than 3 month and must match the address provided in the application; and color copy of the passport.
    

The Applicant, who is a natural person, cannot use a representative in the course of a Business Relationship or Occasional Transaction with the Company.

• For legal entity:
  
  • company details: full name of company, legal form, date of incorporation, company number, country of incorporation, country of taxation, business description (as much detailed as possible), contact person first and last name name, contact person position (within the legal entity), contact person phone number, contact person email address, company website, registered address (street, house number, city, country, postcode/zip code), business address (street, house number, city, country, postcode/zip code); and
    
  • the copies of documents, which prove information stated above: formation documents (e.g., certificate of formation, articles of incorporation, certificate of organization, or equivalent documents); proof of address (e.g., utility bill, bank statement, lease agreement) - this document must be not older than 3 month and must match the address provided in the application;
    
  • bank details (if applicable): bank account holder name, bank account number, bank name, bank SWIFT;
    
  • management details (person with significant responsibility to control, manage, or direct the legal entity): first and last name, date of birth, tax identification number, email, phone number, full permanent address (street, house number, city, country, postcode/zip code), citizenship, confirmation that the person, family member, or a close associate is not a Politically Exposed Person; and
    
  • the copies of documents, which prove information stated above: proof of address (e.g., utility bill, bank statement, lease agreement) - this document must be not older than 3 month and must match the address provided in the application; color copy of the passport;
    
  • corporate structure details: first and last name, date of birth, tax identification number, email, phone number, full permanent address (street, house number, city, country, postcode/zip code), citizenship, ownership interest %, confirmation that the person, family member, or a close associate is not a Politically Exposed Person; and
    
  • the copies of documents, which prove information stated above: proof of address (e.g., utility bill, bank statement, lease agreement) - this document must be not older than 3 month and must match the address provided in the application; color copy of the passport;
    
  • identity of every shareholder being a legal entity (if any): full name of company, legal form of company, date of incorporation, company number, country of incorporation, registered address (street, house number, city, country, postcode/zip code), ownership interest (%); and
    
  • the copies of documents, which prove information stated above: formation documents (e.g., certificate of formation, articles of incorporation, certificate of organization, or equivalent documents);
    
  • ultimate beneficial owners data: first and last name, date of birth, tax identification number, email, phone number, full permanent address (street, house number, city, country, postcode/zip code), citizenship, ownership interest %, confirmation that the person, family member, or a close associate is not a Politically Exposed Person; and
    
  • the copies of documents, which prove information stated above: proof of address (e.g., utility bill, bank statement, lease agreement) - this document must be not older than 3 month and must match the address provided in the application; color copy of the passport;
    
  • business relation details: purpose of the Business Relationship, estimated total number of trades per month, anticipated average trade size (EUR), estimated annual income (EUR), digital assets which Applicant expects to deposit/withdraw in; source of funds details: an Applicant needs to indicate what source of funds will be used to fund trading account (normal commercial activities, business savings & investments, sale of property or business asset); and
    
  • copies of the following documents: (i) memorandum of association, (ii) most recent articles of association/by-laws, (iii) certificate of good standing (not older than 12 months), (iv) certificate of shareholders, (v) certificate of directors; (vi) bank statement (1 year – 3 months); (vii) business plan (business description, web-page information) (if applicable); (viii) a copy of the annual financial statement or audited accounts (if applicable); (ix) supporting documentation of the source of funds.
    

The Company verifies the correctness of the Applicant's data specified above, using information originating from a credible and independent source for that purpose. Where the Company has access to the relevant register of legal entities, the submission of the documents specified above do not need to be demanded from the Applicant.
The identity of legal entity and the right of legal entity's representation can be verified on the basis of a document specified above, which has been authenticated by a notary or certified by a notary or officially, or on the basis of other information originating from a credible and independent source, including means of electronic identification and trust services for electronic transactions, thereby using at least two different sources for verification of data in such an event.

2. POLITICALLY EXPOSED PERSONS IDENTIFICATION

PEP means a natural person who performs or has performed prominent public functions and with regard to whom related risks remain.
The Company shall take measures to ascertain whether the Customer, the Beneficial Owner of the Customer or the representative of this Customer is a PEP, their family member or close associate or if the Customer has become such a person.
The Company shall request from the Customer information to identify if the Customer is a PEP, their family member or close associate (e. g. providing the Customer with an opportunity to specify the relevant information when collecting data about the Customer).
Albeit the Company identifies the PEPs, it does not establish Business Relationships with PEPs and does not conduct Occasional Transactions with PEPs.

3. NOT-ACCEPTABLE CUSTOMERS

The following list predetermines the type of Customers who are not acceptable for establishing a Business Relationship or an execution of an Occasional Transaction with the Company:

• Customers who fail or refuse to submit, the requested data and information for the verification of his identity, without adequate justification;
  
• Shell Banks;
  
• Customers from the jurisdictions which are being banned by internal policies from the company or international sanctions;
  
• Customers who were identified as the persons subject to International Sanction Act;
  
• Customers who were identified as the persons subject to the UN Sanctions; EU Sanctions; Sanctions administered by the Office of Financial Sanctions Implementation, Sanctions administered by the Office of Foreign Assets Control;
  
• the Company suspects money laundering or terrorist financing;
  
• any other that the Company considers risky to its business or suspicious in regards to Money Laundering and Terrorist Financing.
  

The Company will not accept as Сustomers, persons or entitled from Afghanistan, Angola, Algeria, Bahamas, Bangladesh, Bolivia, Botswana, Burma (Myanmar), Burundi, Cambodia, Chad, Gvineja, Côte D'ivoire, Crimea (Ukraine region), Cuba, Democratic People's Republic of Korea, Egypt, Equatorial Guinea, Eritrea, Ghana, Guinea Bissau, Guyana, Iceland, Iran, Iraq, Haiti, Lao PDR, Lebanon, Libya, Mali, Mongolia, Morocco, Myanmar, Nepal, Nicaragua, North Macedonia, Pakistan, Panama, Qatar, Saudi Arabia, Somalia, South Sudan, Sudan, Syria, Trinidad and Tobago, Uganda, United States, Vanuatu, Venezuela, Yemen, Zimbabwe and other countries and jurisdictions, where these services can not be provided by legislation countries.
The Company also does not accept any clients from disputed territories as they do not produce recognised official documents, these include: Donetsk People's Republic (DPR)/Luhansk People's Republic (LPR), Pridnestrovian Moldavian Republic, Nagorno-Karabakh Republic, Republic of Abkhazia, Republic of Somaliland, Republic of South Ossetia, Turkish Republic of Northern Cyprus, Republic of China (Taiwan), Passports issued by the Russian Federation in Crimea and passports issued to residents of Donetsk and Luhansk regions of Ukraine do not qualify for verification, Republic of Kosovo, Sahrawi Arab Democratic Republic, Republic of Artsakh.
Persons or entities from jurisdictions where a particular license or permit is required will not be accepted as Customers if the Company has not received such a permit or license.

4. RISK-BASED APPROACH

The Company identifies the risks/threats related to its activities, as well as the risks/threats that may arise in the near future, that is foreseeable risks/threats, and assesses and analyses their significance and impact. The risks/threats are identified and assessed on a case-by-case basis as of the moment of the risk assessment and separately considering the situation where the Company should take the risks to the maximum extent permitted by the risk appetite. The Company identifies, assesses and analyses risks of money laundering or terrorist financing taking into account the following risk categories:

• risks relating to customers;
  
• risks relating to countries, geographic areas or jurisdictions:
  
• risks relating to products, services or transactions, including risks relating to new and/or future products, services or transactions:
  
• risks relating to communication, mediation or products, services, transactions or delivery channels between the Company and customers.
  

The Company shall identify risk factors for the risk categories specified in above that increase or decrease the risk of money laundering and terrorist financing.

5. REFUSAL TO THE TRANSACTION OR BUSINESS RELATIONSHIP AND THEIR TERMINATION

The Company is prohibited to establish a Business Relationship and the established Business Relationship or transaction shall be terminated (unless it is objectively impossible to do) in case when:

• the Company suspects Money Laundering or Terrorist Financing;
  
• it is impossible for the Company to apply the CDD measures, because the Customer does not submit the relevant data or refuses to submit them or the submitted data gives no grounds for reassurance that the collected data are adequate;
  
• the Customer which capital consists of bearer shares or other bearer securities wants to establish the Business Relationship;
  
• the Customer who is a natural person behind whom is another, actually benefiting person, wants to establish the Business Relationship (a suspicion that a person acting as a front is used);
  
• the Customer's risk profile has become inappropriate with the Company's risk appetite (i. e. the Customer's risk profile level is "prohibited").
  

In the event of a termination of the Business Relationship in accordance with this chapter, the Company shall transfer the Customer's assets within a reasonable time, but preferably not later than within one month after the termination and as a whole to an account opened in a credit institution which is registered or whose place of business is in a contracting state of the European Economic Area or in a country where requirements equal to those established in the relevant directives of the European Parliament and of the Council are applied. In exceptional cases, assets may be transferred to an account other than the Customer's account or issued in cash. Irrespective of the recipient of the funds, the minimum information given in English in the payment details of the transfer of the Customer's assets is that the transfer is related to the extraordinary termination of the Customer relationship.

6. REPORTING OBLIGATION

The Company must suspend the transaction disregarding the amount of the transaction (except for the cases where this is objectively impossible due to the nature of the Monetary Operation or transaction, the manner of execution thereof or other circumstances) and appointed the MLRO who is responsible for the submission of reports to the the Financial Crime Investigation Service ("FCIS"), regular assessment of the Company's AML/CFT procedures and policies (compliance with the respective laws/regulations) and regular reporting to the Company's management board.
The Company will report through its MLRO must report to the FCIS on the activity or the circumstances that they identify in the course of economic activities and whereby:

• the Company has established that the Customer is carrying out a suspicious transaction;
  
• the Company knows or suspects that assets of any value are obtained directly or indirectly from criminal activity or participation in such activity.
  

The Company through its MLRO must send information to the FCIS not later than within 7 working days after the identification of Virtual Currency exchange transactions or transactions in Virtual Currency, if the daily value of such transaction(s) is equal to or exceeds EUR 15,000 or the equivalent amount in foreign or Virtual Currency, regardless of whether the transaction is concluded in one or more related monetary transactions.
The Company, a structural unit of the Company, a Management Board member, MLRO and the Internal Control Officer is prohibited to inform a person, its Beneficial Owner, representative or third party about a report submitted on them to the FCIS, a plan to submit such a report or the occurrence of reporting as well as about a precept made by the FCIS or about the commencement of criminal proceedings.

In case of any doubts or concerns, please contact us at: support@manimama.eu