1. Introduction

1.1 Purpose

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy establishes
the principles and requirements for Pocket Ideas Sp.Z.oo to prevent money laundering and
terrorist financing through our cryptocurrency over-the-counter (OTC) exchange platform.
This policy is designed to ensure compliance with EU regulations, including the 5th and 6th
Anti-Money Laundering Directives (AMLD5 & AMLD6), and Polish VASP requirements.

1.2 Scope

This policy applies to all operations, employees, customers, and partners involved in
cryptocurrency exchange services, including fiat-to-crypto and crypto-to-fiat transactions at
Pocket Ideas Sp.Z.oo.

2. Legal Framework

Pocket Ideas Sp.Z.oo operates under:

• EU Anti-Money Laundering Directives (AMLD5 & AMLD6)
• EU Regulation on the prevention of the use of the financial system for the purposes
  of money laundering or terrorist financing
• Polish Financial Supervision Authority (KNF) regulations
• Virtual Asset Service Provider (VASP) requirements
• The Act on Counteracting Money Laundering and Terrorist Financing
• The Polish Act on Counteracting Terrorism

3. Risk-Based Approach

• Pocket Ideas Sp.Z.oo takes a risk-based approach to AML/CTF compliance, which includes:
• Conducting regular risk assessments to identify, assess, and understand the money
  laundering and terrorist financing risks faced by the organisation.
• Implementing appropriate measures to effectively manage and mitigate the identified
  risks.
• Regularly reviewing the risk assessment and adjusting control measures as
  necessary.

4. Customer Due Diligence (CDD)

4.1 Standard CDD Measures

For all customers, Pocket Ideas Sp.Z.oo collects and verifies the following information:

• Full legal name
• Date of birth
• Residential address
• Official identification document
• Source of funds declaration

4.2 Enhanced Due Diligence (EDD)

EDD is applied to:

• Transactions exceeding risk-based thresholds based on customer profile and
  payment method
• High-risk customers, including those from sanctioned or high-risk jurisdictions
• Politically Exposed Persons (PEPs) and their close associates
• Customers with complex or opaque ownership structures

4.3 Ongoing Monitoring

Pocket Ideas Sp.Z.oo conducts ongoing monitoring of customer relationships, including:

• Regular review of customer profiles
• Transaction pattern analysis
• Update of customer information
• Risk level reassessment

5. Transaction Monitoring

5.1 Monitoring Procedures

Pocket Ideas Sp.Z.oo’s transaction monitoring procedures include:

• Real-time transaction screening against sanctions lists and PEP databases
• Pattern recognition for suspicious activities like round-number transactions, rapid
  fund flows, and unusual transfer routes
• Volume and frequency monitoring to identify unusual transaction patterns
• Integration of blockchain analytics tools to trace fund flows and identify high-risk
  addresses

5.2 Transaction Limits

• Daily and monthly transaction limits based on customer risk profile, payment method,
  and CTF considerations
• Enhanced limits for higher-risk customers and payment methods
• Appropriate cool-down periods between high-value transactions to allow for
  additional screening

5.3 Terrorism Financing Red Flags

Pocket Ideas Sp.Z.oo’s transaction monitoring procedures also screen for indicators of
potential terrorism financing, such as:

• Funds transfers to or from countries known to sponsor terrorism
• Transactions involving individuals or entities on terrorist watchlists
• Unusual cash transactions, especially those structured to avoid reporting
  requirements
• Rapid movement of funds through multiple accounts without a clear business
  purpose

6. Suspicious Activity Reporting

Pocket Ideas Sp.Z.oo has established internal and external reporting procedures for
suspected money laundering or terrorist financing activities, including:

• Clear internal reporting channels for staff to report suspicious activities
• Timely submission of Suspicious Activity Reports (SARs) to relevant authorities
• Cooperation with law enforcement agencies
• Confidentiality and record-keeping measures

7. Record Keeping

Pocket Ideas Sp.Z.oo maintains comprehensive records of all customer identification
information, transaction details, due diligence documents, risk assessments, training
records, and investigation files for a minimum of 5 years. These records are stored securely
and accessed in a controlled manner to ensure data protection and GDPR compliance.

8. Staff Training and Awareness

Pocket Ideas Sp.Z.oo provides ongoing training and awareness programs for all employees,
including:

• Initial AML/CTF training for new hires
• Annual refresher courses
• Role-specific training modules
• Education on recognizing potential terrorism financing red flags
• Procedures for reporting suspected terrorist financing activities
• Updates on applicable laws and regulations

9. Compliance Structure

Pocket Ideas Sp.Z.oo has appointed a dedicated Money Laundering Reporting Officer
(MLRO) who is responsible for overseeing the organisation’s AML/CTF compliance program.
The MLRO reports directly to the Board of Directors and has the necessary authority,
independence, and resources to fulfil their duties effectively.

10. Policy Review and Update

Pocket Ideas Sp.Z.oo regularly reviews and updates this AML/CTF policy to ensure it
remains effective and aligned with changing regulations and industry best practices. The
policy is subject to an annual review, with more frequent updates as required by regulatory
changes or organisational needs.

11. Sanctions and Penalties

Pocket Ideas Sp.Z.oo has established internal disciplinary procedures and remediation
requirements for any compliance breaches by employees. The organisation is also aware of
the applicable regulatory sanctions and penalties for AML/CTF violations and has
implemented appropriate prevention measures and response procedures.