ZixiPay LLC and Delpa Tech UAB (collectively as “ZixiPay”, “we” and “us”) has implemented its Know Your Customer, Anti-Money Laundering and Combating the Financing of Terrorism Policy (hereinafter - the “KYC/AML/CFT Policy”) to prevent and mitigate possible risks of ZixiPay being used in any kind of illegal activities. As required by EU directives and recommendations of FATF, ZixiPay has implemented effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its users.

Summary of our internal AML policy:

1. Know your customer (KYC)

ZixiPay adheres to a robust KYC verification process, meticulously gathering and verifying all necessary information related to the client and individuals within the client's corporate framework. The creation of anonymous accounts is strictly prohibited. Compliance with the KYC protocol, including the completion of the requisite questionnaire and mandatory video verification, is imperative.

2. Transactions monitoring (KYT)

ZixiPay conducts a thorough verification process encompassing client reputation, geographical location, and license(s). Clients are permitted to designate only one bank account for all transactions, with deposits and withdrawals exclusively facilitated through the declared account. Real-time monitoring of virtual currency transactions is a standard practice at ZixiPay. In the event of detected evidence or indications of suspicious activities, such as crypto replenishments from untrusted sources or actions exhibiting characteristics of fraud, ZixiPay reserves the prerogative to initiate an internal investigation, suspend or close the client's account, nullify any pending payments, and temporarily halt service provision. Instances of suspicious transactions are promptly reported to the relevant authorities.

3. AML/Sanctions screening

ZixiPay employs rigorous safeguards to prevent involvement in money laundering and terrorist financing. This includes thorough screening of all clients, encompassing controllers and beneficial owners, with a dedicated focus on sanctions screening. ZixiPay maintains a comprehensive obligation to retain current and pertinent information regarding clients' beneficial ownership, conducting periodic re-checks on clients and their activities to ensure ongoing compliance.

4. Services availability

ZixiPay refrains from offering services to individuals situated in jurisdictions flagged by the EU and FATF as high-risk and non-cooperative, characterized by significant anti-money laundering and counter-terrorist financing deficiencies. Additionally, ZixiPay does not extend its services to citizens and residents of the United States.

5. Risk assessment

ZixiPay employs a comprehensive Risk-Based Approach throughout its operations. This involves the systematic identification, assessment, comprehension, and mitigation of AML/CTF (Anti-Money Laundering/Counter-Terrorist Financing) risks, taking into account factors like customer profiles, product characteristics, geographic considerations, and distribution channels.