AML & KYC

Introduction

The Anti-Money Laundering and Know Your Customer Policy of Invertox LTD. (the "Company") (hereinafter, the "AML/KYC Policy") is designed to prevent and mitigate potential risks of the Company being involved in any type of illegal activity.

The phrase "money laundering" covers all procedures to conceal the origins of the proceeds of crime so that they appear to come from a legitimate source. Invertox LTD. ("Company") aims to detect, manage, and mitigate the risks associated with money laundering and terrorist financing.

Both international and local regulations require Invertox LTD. to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery, and to take action in case of any form of suspicious activity by its Users.

The AML/KYC policy covers the following matters:

1. Verification procedures
2. Sanctions and PEP lists analysis
3. Compliance Officer
4. Transaction monitoring
5. Risk assessment

1. Verification Procedures

One of the international standards for preventing illegal activities is Customer Due Diligence ("CDD"). According to CDD, Invertox LTD. establishes its own verification procedures within the anti-money laundering standards and "Know Your Customer" frameworks.

1.1. Identity Verification

Registration process on the portal: an individual client provides the following identification information to the company:

• Client's full name;
• Client's date of birth;
• Client's country of residence/location;
• Mobile phone number and email.

During the registration process on the Invertox LTD. Portal, a corporate client provides the following Company information:

• Full company name;
• Registration number and date;
• Country of registration/incorporation;
• Registered address;
• Mobile phone number and email.

After receiving the identification information, the Company's personnel must verify this information through the identity verification procedure.

The identity verification procedure of Invertox LTD. requires the User to provide the Company with reliable and independent documents, data, or information (e.g., national identification, international passport, bank statement, utility bill). For such purposes, the Company reserves the right to collect identification information from the Client for the purposes of the AML/KYC Policy.

Invertox LTD. will take steps to confirm the authenticity of the documents and information provided by Clients. All legal methods will be used to verify identification information, and the Company reserves the right to investigate certain clients who have been determined to be risky or suspicious.

Invertox LTD. reserves the right to verify the Client's identity on an ongoing basis, especially when their identification information has been modified or their activity appears suspicious (unusual for the client). Additionally, Invertox LTD. reserves the right to request updated documents from clients, even if they have passed identity verification in the past.

Client identification information will be collected, stored, shared, and strictly protected in accordance with Invertox LTD.'s Privacy Policy and related regulations.

Once the Client's identity has been verified, Invertox LTD. may be exempt from possible legal liability in a situation where its Services are used to carry out illegal activities.

Client identification procedures and customer due diligence measures will comprise:

(a) Identifying the Client and verifying their identity on the basis of documents, data, or information obtained from a reliable and independent source.

(b) Identifying the beneficial owner and taking adequate and risk-based measures to verify identity on the basis of documents, data, or information obtained from a reliable and independent source, so that the person conducting financial or other business knows who the beneficial owner is. With regard to legal persons, trusts, and similar legal arrangements, taking adequate and risk-based measures to understand the ownership and control structure of the Client.

(c) Obtaining information on the purpose and intended nature of the business relationship.

(d) Conducting ongoing monitoring of the business relationship, including scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the information and data held by the person engaging in financial or other business in relation to the Client, the business, and the risk profile, including where necessary, the source of funds and ensuring that the documents, data, or information held are kept up-to-date.

(e) Screening Clients against databases or third-party checks to detect adverse news related to taxes.

(f) Maintaining records of the ultimate beneficial owners of clients that must be accessible to law enforcement agencies.

1.2. Proof of Residency Requirements

• Recent utility bill (i.e., electricity, water, telephone, gas): the bill must be less than three (3) months old. Please note that a mobile phone bill will be accepted as valid proof of residency only if the name on the bill matches the name on the registration and the same applies to the phone number.
• Recent bank statement: must be less than three (3) months old.

Important: Screenshots of bank statements are only acceptable in cases where the bank account used as proof of address is the same as the one used to deposit funds into the account.

• Recent mortgage statement.
• Signed lease agreement still within term.
• Bank, Investment Letter.
• National Passport.

PLEASE NOTE that any document that has been used as proof of identity cannot also be used as proof of address, except for the national passport mentioned above.

• Deed or other evidence of ownership;
• Homeowner's or renter's insurance policy bill (less than six (6) months old);
• Security System Bill/Statement (less than six (6) months old);
• Government-issued letters or statements establishing current address (less than twelve (12) months old).

For example:

• Tax letters and notices;
• Letters or notices from government housing authorities;
• Jury service notices;
• Voter registration notices;
• Other official government letters or notices showing the name and address of the client being verified.

Proof of residency must:

• Show current address
• Show name as stated on the account application
• Be from a credible source (with a visible logo)
• Be dated within the last three (3) months

NOTE: In cases where none of the above are available, the following are acceptable as other forms of Proof of Residency for locals:

• Proof of residency from the Municipality, Property Registry

The following are acceptable as other forms of proof of residency for non-locals:

• Valid lease agreement (one year) between the client and the landlord or between the company employing our client and the landlord associated with the employment contract or a letter from the company stating our client's employment duly signed by the company.

1.3. Joint Account – Required Documents

A joint account is made between 2 clients. Both clients must be fully verified to proceed with approval.

Once we receive the internal joint account application form, we verify if it is completed and signed by both clients.

• Married couples: proof of marriage required
• Family related in the first degree: proof required, such as a birth certificate
• Unrelated but with a joint bank account: joint bank statement and proof of relationship required.

In most cases, both account holders will submit the aforementioned documents for individuals. If additional documents are required, the client will be contacted by email.

1.4. Corporate Account Information

• Certificate of Incorporation
• Memorandum and Articles of Association
• Certificate of Registered Office
• Memorandum and Articles of Association
• Certificate of Incumbency
• Certificate of Incumbency
• Certificate of Directors and Secretary
• Certificate of Shareholders
• A board resolution for opening the account and granting authority to those who will operate it
• Proof of Identification for Shareholder(s)/Director(s)/Secretary/UBO
• Proof of Residency for Shareholder(s)/Director(s)/Secretary/UBO

2. Sanctions and PEP Lists Screening

Invertox LTD. screens applicants against recognized sanctions and Politically Exposed Persons (PEP) lists.

Natural and legal persons are screened against the mentioned lists:

• At the incorporation stage when the user submits the application.
• In each anti-fraud and AML alert manually by the Compliance Officer.
• Daily automatically running with a script to re-verify all client databases.

To perform the screening process, Invertox LTD. uses an internal system supported by World-Check and other official lists.

World Check search tool (provided by Refinitiv) for manual confirmation.

3. Compliance Officer

The Compliance Officer is the person, duly authorized by Invertox LTD., whose duty is to ensure the effective implementation and compliance of the AML/KYC Policy. It is the responsibility of the Compliance Officer to oversee all aspects of Invertox LTD.'s anti-money laundering and terrorist financing efforts, including, but not limited to:

1. Collecting identification information from Users.
2. Establishing and updating internal policies and procedures to complete, review, submit, and retain all required reports and records according to applicable laws and regulations.
3. Monitoring transactions and investigating any significant deviation from normal activity.
4. Implementing a record management system for proper storage and retrieval of documents, files, forms, and records.
5. Periodically updating the risk assessment.
6. Providing authorities with required information according to applicable laws and regulations.

Invertox LTD, in accordance with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, Invertox LTD. can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks. This will allow resources to be allocated in the most efficient way. The principle is that resources should be directed according to priorities so that the greatest risks receive the most attention.

The Compliance Officer has the right to interact with law enforcement authorities involved in preventing money laundering, terrorist financing, and other illegal activities.

4. Transaction Monitoring

Clients are known not only by verifying their identity but, more importantly, by analyzing their transactional patterns. Therefore, Invertox LTD. relies on data analysis as a risk assessment and suspicion detection tool. Invertox LTD. performs a variety of compliance-related tasks, including data capture, filtering, record keeping, investigation management, and reporting. System functionalities include:

1) Daily screening of Users against recognized "blacklists" (e.g., OFAC), adding transfers using multiple data points, placing Users on watchlists and denial of service lists, opening cases for investigation when necessary, sending internal communications, and completing legal reports, if applicable;

2) Case and document management.

With respect to the AML/KYC Policy, Invertox LTD. will monitor all transactions and reserves the right to:

• Ensure that transactions of a suspicious nature are reported to the competent authorities through the Compliance Officer.
• Request the client to provide any additional information and documents in case of suspicious acts.
• Suspend or terminate the Client's Account when Invertox LTD. has a reasonable suspicion that such client is involved in illegal activities.

The above list is not exhaustive, and the Compliance Officer will monitor client transactions day-to-day to define whether such transactions should be reported and treated as suspicious or if they should be treated as in good faith.

5. Risk Assessment

Invertox LTD., in accordance with international requirements, has adopted a risk-based approach to combat money laundering and terrorist financing. By adopting a risk-based approach, Invertox LTD. can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks. This will allow resources to be allocated in the most efficient way. The principle is that resources should be directed according to priorities so that the greatest risks receive the most attention.

For more information, contact us at: support@invertox.com.