Introduction

This policy confirms ROXA DIGITAL LTD’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

ROXA DIGITAL LTD has established Know Your Client (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.

The Managing Director is responsible for development and implementation of this policy and relevant procedures, and ROXA DIGITAL LTD commits to review our KYC policy and procedure every year.

To support our KYC policy and procedures, ROXA DIGITAL LTD has developed a KYC form which we send to all our customers to collect relevant business information to identify risks of money-laundering. We require the form to be completed for all existing and new customers.

By collecting and reviewing the information in completed KYC forms, [ROXA DIGITAL LTD commits to

• establishing the identity of our customers
• checking that our customers are not considered high-risk (this means checking whether customers are based in FATF high-risk jurisdictions, named on government sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas
• maintaining an understanding of the nature and legitimacy of all our customers’ businesses
• maintaining KYC records for at least 3 years
• maintaining records of all single or linked cash (or cash-like) transactions above 10,000EUR
• monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

If customers are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

• Cease trading with the customer
• Identify the customer and check whether the customer is on any watchlists or sanctions list
• Make an on-site visit to the high-risk customer.