AML/CTF Policy

Purpose and Scope

The Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policy of INFINITY sp. z o. o. is designed to identify, prevent, and mitigate the risks associated with potential involvement in illegal activities. This policy is essential for ensuring that INFINITY sp. z o. o. remains compliant with both international and local regulations, and it outlines the measures taken to safeguard against money laundering, terrorist financing, and other financial crimes.

Understanding the Risk Environment

Financial institutions, particularly those related to cryptocurrency exchanges, frequently encounter attempts to launder money or finance terrorism. AML laws, regulations, and procedures aim to prevent criminals from legitimizing illegally obtained funds. Terrorist financing encompasses not only the direct funding of terrorist activities but also related activities such as fundraising, possession of funds, and financing arrangements.

Commitment to Compliance

INFINITY sp. z o. o. is fully committed to closely monitoring and addressing any activity that might suggest money laundering or terrorist financing. To align with global and local regulations, we have instituted robust internal procedures to combat money laundering, terrorist financing, drug and human trafficking, weapons proliferation, corruption, and bribery. These procedures also ensure appropriate action is taken whenever suspicious activities are detected.

Key Components of the AML/CTF Policy

1. Verification Procedure

Before any client can access the services offered by INFINITY sp. z o. o., their identity must be verified. This is a crucial step in preventing money laundering and terrorist financing. The law mandates that financial institutions must gather, verify, and record information that identifies individuals or entities seeking to conduct business with us. This information includes, but is not limited to, names, addresses, dates of birth, and other relevant details about the customer or their organization.

Clients deemed to pose a higher risk may undergo more intensive scrutiny, which may involve additional information requests and extended verification processes.

INFINITY sp. z o. o. reserves the right to conduct ongoing verification, especially if a client’s identification details change or if their activities appear suspicious or unusual. We may also request up-to-date documentation, even if the documents were previously authenticated.

All customer identification information will be collected, stored, shared, and protected in strict accordance with INFINITY sp. z o. o.’s Privacy Policy and applicable regulations.

2. Risk Assessment

INFINITY sp. z o. o. adopts a risk-based approach to AML and CTF obligations, enabling the identification, assessment, and understanding of the risks associated with money laundering and terrorist financing. This approach allows us to implement appropriate measures that correspond to the level of identified risk.

Risk Categories:

Customer Risk: This includes factors such as discrepancies in identification documents, fictitious identities, stolen or counterfeit identification documents, use of a P.O. box address, history of financial crimes, terrorist affiliations, or lack of valid contact information. It also includes risks associated with Politically Exposed Persons (PEPs), such as heads of state, government ministers, members of parliament, senior military officers, and high-ranking officials in state-owned enterprises or international organizations.

Country Risk: The Anti-Money Laundering Directive requires enhanced due diligence for business relationships or transactions involving high-risk third countries. This involves obtaining additional information on the customer and beneficial owner, sources of funds, reasons for the transaction, and securing senior management approval before establishing or continuing such relationships.

3. Monitoring Customer Activities

INFINITY sp. z o. o. continuously monitors customer activities both in real-time and retrospectively to detect any potential fraudulent, illegal, or unauthorized behavior. All transactions are subject to scrutiny, and any suspicious activity is thoroughly investigated. If necessary, such activities are reported to the relevant authorities, and additional restrictive measures may be implemented to prevent money laundering or terrorist financing.

In cases where suspicious transactions are identified, INFINITY sp. z o. o. may request further information and documentation from the client. Should there be reasonable suspicion of illegal activities, INFINITY sp. z o. o. may suspend or terminate the client’s account.

4. Reporting Suspicious Activities

In accordance with its AML/CTF Policy and legal obligations, INFINITY sp. z o. o. will report any activities suspected of involving money laundering or terrorist financing to the appropriate authorities. Such reports are made without notifying the client or addressing any inquiries related to the report.