1. General

To monitor the accordance with recommendations of FATF, LIBRA EXCHANGE (SV) LLC (working under trade name ELIBRAX) has established a Compliance department responsible for Anti-money laundering and Know your customer (AML & KYC) procedures, obligatory for all employees and determining the policy of engagement with any company which uses ELIBRAX service.

This summary describes base points of Company's internal AML policy:

2. Know your customer

ELIBRAX follows a strong process of KYC verification in order to collect and check all required information about the client and persons in corporate structure. Opening anonymous accounts is restricted. Upon the request of the Company additional documents and information should be provided by the client. Refuse to provide documents on Company’s compliance request may lead to suspending or termination of relationships with the Company. Filling of respective KYC questionnaire, passing liveness check and videoverification are also an obligatory requirements of Company.

3. Monitoring transactions

ELIBRAX verifies client bank's reputation, geographic location and license. The client is allowed to declare only one bank account for transactions, and all deposits and withdrawals are allowed only from/to the declared account. The Company performs real-time checks of transactions. In case of the evidence or signs of suspicious transactions at the client’s account, cash or crypto replenishments from untrusted sources and / or any actions with attributes of fraud, the Company reserves the right to conduct an internal investigation, to block or close the Customer’s Account, cancel any payment and to suspend providing services.

4. AML/Sanctions screening

ELIBRAX is protected against involvement in money laundering and terrorist financing through the screening of all clients (including controllers and beneficial owners), including sanctions screening. The Company also has an overall obligation to hold adequate and up to date information on clients’ beneficial ownership and conducts regular re-checks on clients and their activity.

5. Monitoring clients for suspicious activity

We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. Monitoring will be conducted through the following methods: CO will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities. ELIBRAX denies politically exposed persons in service. ELIBRAX requests clients to provide documents on origin of funds in amounts of more than 15.000 EUR (client's welfare).

We will conduct the following reviews of activity that our monitoring system detects: Complete Account Review. We will document our monitoring and reviews as follows: according to AML Compliance. The AML Compliance Person or his or her designee will conduct an appropriate investigation and review relevant information from internal or third- party sources before a STR is filed.

ELIBRAX prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by checking all clients on the follow sanction lists of OFAC (Office of Foreign Assets Control), UK (HMT) - sanctions regimes implemented in the UK, Europe Union sanction list and sanction lists of United Nations Security Council:OFAC list (Office of Foreign Assets Control)

United Nations Security Council Consolidated List

The UK sanctions list

Consolidates list of financial sanctions targets in the UK

Europe Union Consolidated Financial Sanctions List

6. Geographic of providing services

The Company doesn't provide services to the persons who located at the jurisdictions that are identified by the FATF as high risk and non-cooperative jurisdictions having strategic AML/CFT deficiencies, according to official lists (including Iran, North Korea, etc.).

7. Risk assessment

The Company applies a Risk Based Approach across the business, this requires identification, assessment, understanding and mitigation of AML/CTF risk including considering risk factors such as customer, product, geography and channel.