ANTI-MONEY LAUNDERING (AML) AND KNOW YOUR CUSTOMER (KYC) POLICY

Last updated: May 2026

FISKL SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (the “Company”) operates under strict regulatory oversight as a licensed Virtual Asset Service Provider (VASP) in Poland (Registration No. RDWW-1093). The Company maintains comprehensive anti-money laundering (AML) and counter-terrorist financing (CTF) frameworks in strict accordance with the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, as well as European Union AML Directives.

1. Objectives and Compliance Supervision

The primary objective of this Policy is to prevent the Company’s financial infrastructure, corporate exchange accounts (Binance, KuCoin), and electronic payment channels (Wise) from being utilized for illicit activities. Compliance procedures are strictly managed by the designated internal compliance department under the supervision of the Management Board and its President, Verners Runde.

2. Customer Due Diligence (CDD) and KYC Verification

The Company enforces compulsory identification and verification processes for all Clients before executing any exchange transactions. Anonymous operations are strictly prohibited. The verification process requires the submission of:

  • A valid, high-resolution copy of a government-issued identification document (Passport or National ID card).
  • Proof of residential address issued within the last 3 months (utility bill, bank statement, or official governmental correspondence).
  • Corporate verification documentation (if the transaction is executed on behalf of a legal entity).

3. Transaction Monitoring and Enhanced Due Diligence (EDD)

All operational flows, crypto-to-fiat, and fiat-to-crypto exchanges are subjected to continuous manual and automated transaction monitoring. Enhanced Due Diligence (EDD) procedures are automatically triggered if a Client’s transaction patterns indicate elevated risks, involve Politically Exposed Persons (PEPs), or exceed standard threshold limits. Under EDD, Clients must provide legally verifiable Proof of Source of Funds (e.g., bank statements, tax returns, or official corporate profit declarations).

4. Sanction Screening and International Compliance

The Company cross-references all Client records against mandatory international sanction matrices, including lists maintained by the United Nations, the European Union, and the United States Office of Foreign Assets Control (OFAC). The Company does not open accounts or execute transactions for individuals or corporate entities subject to international financial sanctions or hailing from high-risk uncooperative jurisdictions.

5. Reporting and Data Retention

In full compliance with Polish statutory laws, the Company is legally obligated to report suspicious transactions or attempted illicit operations directly to the General Inspector of Financial Information (GIIF). In line with AML regulations, all collected verification records, transaction logs, and correspondence are securely archived for a minimum period of 5 years after the corporate relationship is dissolved.