AML POLICY

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML Policy”) sets out the principles and procedures applicable to the use of LICOVIA services.

The LICOVIA platform is operated in connection with:

For the purposes of this AML Policy, “Company” refers to ALTRIUM AG and “LICOVIA” refers to the platform, products, interfaces and services made available to Users.

By accessing or using LICOVIA services, Users agree to comply with this AML Policy and all applicable verification and compliance requirements.

LICOVIA and the Company do not tolerate the use of their services for money laundering, terrorist financing, sanctions evasion, fraud or other unlawful activities.

This AML Policy applies to Users who access, register for or use LICOVIA products, services, platforms or technology solutions. It may apply to prospective customers undergoing onboarding, active customers using the Platform, parties initiating or receiving transactions and Users interacting with wallets, payment functions or supported digital assets.

Failure to comply with applicable AML requirements may result in restrictions, suspension or termination of access to Services and, where legally required, reporting to the relevant authorities.

User / Customer

Any individual or legal entity accessing, registering for or using the Services.

Services

The products, functionalities and technology made available through LICOVIA, including supported payment functionality, account management, wallet functionality, digital-asset functionality and related services.

Platform

The applications, systems, interfaces, APIs and technical infrastructure used to provide LICOVIA Services.

Customer Due Diligence (CDD)

Measures used to identify and verify a User, understand the purpose and nature of the business relationship and assess the associated risk.

Enhanced Due Diligence (EDD)

Additional verification or monitoring measures that may be applied where a User, transaction, jurisdiction or activity presents an increased level of risk.

KYC / KYB

Processes used to identify and verify individuals and businesses and, where applicable, their beneficial owners and authorised representatives.

Risk-Based Approach (RBA)

The application of AML/CFT measures according to the assessed level of risk associated with a User, transaction, product or jurisdiction.

Transaction Monitoring

The review and analysis of transactions for unusual patterns, inconsistencies or potentially suspicious activity.

Blockchain Monitoring

The assessment of blockchain transactions, wallet addresses, counterparties and potential exposure to high-risk or illicit activity.

Sanctions Screening

The screening of Users, counterparties, transactions and, where applicable, blockchain addresses against relevant sanctions lists.

Before access to certain LICOVIA Services is granted, Users may be required to complete identity or business verification. Depending on the nature of the User and the Services requested, information may include:

• identity and contact information;
• company and registration information;
• beneficial ownership information;
• authorised representatives;
• purpose and intended nature of the business relationship;
• source of funds or source of wealth where required;
• expected transaction activity; and
• additional documentation where necessary for compliance or risk assessment.

Access to certain Services may remain restricted until the required verification has been completed.

CDD measures may be applied during onboarding and throughout the business relationship. These measures may include verification of submitted information, assessment of the User's risk profile, review of the intended use of the Services and checks required to understand the nature of relevant transactions. Additional information may be requested where necessary.

Enhanced Due Diligence may be applied in circumstances presenting increased AML/CFT or sanctions risk. This may include additional information or documentation, further verification of source of funds or source of wealth, enhanced transaction review or additional approval requirements. The application of EDD depends on the circumstances and assessed risk.

AML and compliance measures are applied using a risk-based approach. Relevant factors may include:

• customer type;
• business activity;
• jurisdiction;
• transaction behaviour;
• transaction size or frequency;
• payment methods;
• digital assets or blockchain networks involved;
• counterparties;
• sanctions exposure; and
• other relevant risk indicators.

Risk assessments may be reviewed and updated throughout the business relationship.

Transactions may be monitored to identify unusual, inconsistent or potentially suspicious activity. Monitoring may include patterns of transactions, transaction frequency, counterparties, jurisdictions and activity inconsistent with the known profile or expected use of the User.

Where additional clarification is required, Users may be asked to provide further information or supporting documentation.

Where digital assets are involved, blockchain activity may be assessed using appropriate monitoring and risk-analysis processes. This may include the assessment of wallet addresses, transaction history, counterparties and potential exposure to sanctioned, illicit or otherwise high-risk activity. Transactions or wallet activity presenting unacceptable risk may be restricted or subject to further review.

Users and relevant transactions may be screened against applicable sanctions lists and other compliance databases. Where a potential match or elevated sanctions risk is identified, access to Services or individual transactions may be delayed, restricted or subject to additional review.

Verification and compliance obligations do not necessarily end after onboarding. User information, risk profiles and transaction activity may be reviewed throughout the business relationship. Users may be required to update information or provide additional documentation where circumstances change or where necessary to meet compliance requirements.

LICOVIA Services must not be used for activities involving or facilitating:

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• proceeds of crime;
• unlawful transactions; or
• other prohibited or illegal activities.

Potentially suspicious activity may be investigated and handled in accordance with applicable requirements.

Where legally required, information may be reported to competent authorities.

Users are responsible for providing accurate, complete and current information.

Users must respond to legitimate requests for information or documentation relating to verification, transactions or compliance.

Users must not attempt to conceal beneficial ownership, transaction origin, transaction destination or the true purpose of activity conducted through the Services.

Providing false, misleading or fraudulent information may result in restriction or termination of access to Services.

The Company may restrict, suspend or terminate access to Services where required for compliance, risk management, security or legal reasons. Individual transactions may also be delayed, rejected or subject to additional review where necessary.

Nothing in this Policy guarantees approval of an account, transaction, wallet, payment or digital-asset activity.

Certain LICOVIA Services may rely on third-party technology, payment, verification, compliance, digital-asset or infrastructure providers.

Where applicable, additional verification, compliance requirements, restrictions or terms imposed by such providers may apply. The availability of individual Services may therefore depend on the relevant product, jurisdiction, currency, digital asset, blockchain network and applicable compliance requirements.

This AML Policy may be amended from time to time to reflect changes to the Services, compliance procedures, applicable requirements or the LICOVIA operating environment. The current version will be made available through the LICOVIA Platform.

Questions concerning this AML Policy or compliance matters may be directed through the official LICOVIA support channels.