At Acebit.co, we are dedicated to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. As a Virtual Asset Service Provider (VASP) registered and operating in the Republic of Lithuania, we implement robust internal controls and procedures to detect, prevent, and report any activity that may be related to money laundering or the financing of terrorism.

This AML policy is developed in accordance with the following legal and regulatory frameworks:

• The Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania;
• The requirements issued by the Financial Crime Investigation Service (FCIS) under the Ministry of the Interior of Lithuania;
• The European Union's Anti-Money Laundering Directives, specifically AMLD5 and AMLD6;
• The recommendations and guidelines of the Financial Action Task Force (FATF), the global standard-setting body for AML/CTF.

By adhering to these standards, we aim to uphold the integrity of the financial system, promote transparency, and foster a secure environment for cryptocurrency transactions both within Lithuania and globally.

We enforce stringent Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures as a fundamental part of our Anti-Money Laundering framework. These procedures are designed to ensure that we accurately identify and verify the identity of all users prior to establishing a business relationship or facilitating any transactions.

We collect and validate key customer information, including but not limited to:

1. Full legal name
2. Date of birth
3. Residential address
4. Government-issued identification (e.g., passport, national ID card)

Where applicable, we also collect and verify additional documents to support the accuracy and legitimacy of the provided information.

In accordance with risk-based principles, Enhanced Due Diligence (EDD) is applied to customers identified as posing a higher risk, such as:

1. Politically Exposed Persons (PEPs)
2. Individuals or entities operating in or from high-risk jurisdictions
3. Customers whose transaction patterns deviate from expected behavior

We continually monitor customer activity to ensure that the information remains accurate and that no suspicious activity goes undetected. These processes are aligned with applicable laws.

We utilize advanced, automated transaction monitoring systems to detect, assess, and respond to suspicious or potentially illicit activity in real time. Our monitoring framework is designed to ensure ongoing compliance with applicable AML/CTF regulations and to safeguard the integrity of our platform.

All user transactions are continuously analyzed against a set of predefined risk indicators, including but not limited to:

1. Unusual or inconsistent transaction patterns
2. Large or rapid movement of funds inconsistent with the customer profile
3. Transactions involving high-risk jurisdictions or sanctioned entities
4. Structuring or "smurfing" behavior intended to avoid reporting thresholds

Transactions that meet specific risk thresholds or trigger alerts are subject to enhanced scrutiny and, where necessary, escalated to our Compliance Team for further investigation.

Where suspicious activity is identified, appropriate action is taken, which may include:

• Requesting additional information or documentation from the customer
• Temporarily suspending account activity
• Filing a Suspicious Transaction Report (STR) with the Financial Crime Investigation Service (FCIS) of Lithuania

Our transaction monitoring procedures are regularly reviewed and updated to remain aligned with evolving regulatory requirements and emerging typologies of financial crime.

We maintain clear procedures for the timely escalation and reporting of transactions or behaviors deemed suspicious. When such activity is detected, it is promptly reviewed by the Compliance Team, and where necessary, a Suspicious Transaction Report (STR) is submitted to the Financial Crime Investigation Service (FCIS) in accordance with Lithuanian law.

We strictly adhere to confidentiality requirements, including non-disclosure to customers involved in reported activities. All reports are securely documented, and appropriate cooperation is extended to regulatory and law enforcement authorities as part of ongoing investigations or audits.

We store and maintain detailed records of all customer interactions, transactions, and AML compliance activities. These records are retained in accordance with the legal requirements, specifically the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, and for a minimum period of 8 years.

All records are securely stored and are readily accessible to authorized regulatory authorities upon lawful request.

We ensure that all employees undergo regular and comprehensive training on our AML policies and procedures. This training is designed to equip staff with the knowledge and skills required to effectively identify, report, and respond to potential money laundering and terrorist financing activities.

Training programs cover:

1. A thorough understanding of regulatory requirements and obligations;
2. Techniques for recognizing suspicious activities and red flags;
3. Protocols for securely handling sensitive customer information and maintaining confidentiality;
4. All employees receive ongoing updates to keep them informed of changes in regulatory requirements and emerging risks.

We have appointed a dedicated AML Compliance Officer who is responsible for overseeing the implementation, monitoring, and enforcement of our Anti-Money Laundering policies. The Compliance Officer ensures that our practices are in full compliance with current regulations and align with industry best practices.

This individual is also tasked with regularly reviewing our AML procedures to ensure their effectiveness, and serves as the primary point of contact for regulatory authorities and law enforcement agencies when required.

We conduct an annual review of our AML policies to ensure they remain effective and compliant with any changes in applicable laws, regulations, and emerging risks. We are committed to continuously improving our AML framework, adapting to evolving regulatory requirements, and implementing best practices in the prevention of money laundering and terrorist financing.

Where necessary, we update our policies to reflect any significant changes in the regulatory landscape or operational needs.

We are fully committed to upholding the highest standards of anti-money laundering (AML) compliance. We continuously review and update our AML policies to ensure they align with the latest regulations, industry best practices, and emerging risks.

Our proactive efforts to detect, prevent, and report suspicious activities are integral to safeguarding the integrity of our operations. We also contribute to global efforts to combat financial crime, working in partnership with regulators, law enforcement, and other financial institutions to promote a secure and transparent financial ecosystem.

We are committed to ensuring that our platform is free from money laundering and terrorism financing risks. As part of our due diligence process, we will screen the following individuals and entities against relevant sources of information related to money laundering and terrorism financing:

1. Customers
2. Natural persons appointed to act on behalf of customers
3. Related parties of customers
4. Beneficial owners of customers

We will screen the above individuals and entities against various lists and information sources provided by the relevant regulatory authorities to assess the risk of money laundering or terrorism financing. This screening will be conducted under the following circumstances:

• Upon establishing a business relationship with a customer, or as soon as reasonably practicable thereafter.
• Before executing any transaction for a customer who has not otherwise established a business relationship with us.
• Before facilitating or receiving digital assets by value transfer for a customer who has not otherwise established a business relationship with us.
• Periodically, after we have established a business relationship with the customer.

When there are any changes or updates to:

• The lists and information provided by the relevant authorities.
• The natural persons appointed to act on behalf of a customer, their related parties, or beneficial owners.

We will also screen all value transfer originators and value transfer beneficiaries against the relevant lists and information provided by the authorities to detect any potential money laundering or terrorism financing risks.

All screening results will be documented and maintained as part of our compliance records.

We recognize that certain circumstances may indicate that a customer presents, or may present, a higher risk for money laundering or terrorism financing. These circumstances include, but are not limited to, the following:

1. Countries or Jurisdictions Subject to FATF Countermeasures

If a customer, or any beneficial owner of the customer, is from or in a country or jurisdiction for which the Financial Action Task Force (FATF) has called for countermeasures, we will treat any business relationship or transaction involving such a customer as presenting a higher risk for money laundering or terrorism financing.

2. Countries with Inadequate AML/CFT Measures

If a customer, or any beneficial owner of the customer, is from or in a country or jurisdiction known to have inadequate Anti-Money Laundering (AML) or Counter-Terrorist Financing (CFT) measures, as determined by us or notified by the relevant authorities (such as the Financial Crime Investigation Service (FCIS) or other foreign regulatory authorities), we will assess whether such a customer presents a higher risk for money laundering or terrorism financing.

In such cases, we will apply Enhanced Customer Due Diligence (CDD) measures to mitigate the risks associated with these higher-risk customers. Enhanced measures may include additional verification of the customer's identity, sources of funds, and ongoing monitoring of transactions.

We will also perform enhanced CDD for any customer that the relevant authorities notify us of as presenting a higher risk for money laundering or terrorism financing.

In line with our commitment to maintaining a secure platform and preventing money laundering or terrorism financing, we adhere to the following guidelines regarding bearer negotiable instruments and cash payouts:

1. Bearer Negotiable Instruments

We shall not make any payments in the form of bearer negotiable instruments. This includes any form of negotiable instruments that are payable to the bearer and can be transferred without identification.

2. Cash Payouts

We shall not make any cash payments in any amount in the course of carrying on our business. All transactions and payouts will be executed through secure, traceable digital channels.

Our approach to AML compliance is proactive, and we remain dedicated to keeping our systems and procedures up-to-date with global standards. We understand that financial crime risks evolve, and we are prepared to respond accordingly. Our AML framework is built to adapt to changing regulations, emerging threats, and new opportunities for innovation in the cryptocurrency space.

We will continue working with regulatory authorities, law enforcement, and other financial institutions to maintain the highest levels of compliance and transparency.

If you have any question regarding our AML Policy, please contact us at:

• Phone: +44 1245 730049
• Address: ChainHold UAB, registered office address at: Vilnius, Labdarių g. 6A-18, LT-01120, Lithuania.
• Email: [email protected]