1. General

To monitor the accordance with recommendations of FATF, LP FLOW LTD (hereinafter “Company” or “LP FLOW”) has established a Compliance department responsible for Anti-money laundering and Know your customer (AML & KYC) procedures, obligatory for all employees and determining the policy of engagement with any company which uses Company’s service.

This summary describes base points of Company’s internal AML policy:

2. Know your customer

LP FLOW follows a strong process of KYC verification in order to collect and check all required information about the client and persons in corporate structure. Opening anonymous accounts is restricted. Upon the request of the Company additional documents and information should be provided by the client. Refuse to provide documents on Company’s compliance request may lead to suspending or termination of relationships with the Company. Filling of respective KYC questionnaire, passing liveness check and videoverification are also an obligatory requirements of Company.

3. Monitoring transactions

LP FLOW verifies client bank’s reputation, geographic location and license. The client is allowed to declare only one bank account for transactions, and all deposits and withdrawals are allowed only from/to the declared account. The Company performs real-time checks of transactions. In case of the evidence or signs of suspicious transactions at the client’s account, cash or crypto replenishments from untrusted sources and / or any actions with attributes of fraud, the Company reserves the right to conduct an internal investigation, to block or close the Customer’s Account, cancel any payment and to suspend providing services.

4. AML/Sanctions screening

LP FLOW is protected against involvement in money laundering and terrorist financing through the screening of all clients (including controllers and beneficial owners), including sanctions screening. The Company also has an overall obligation to hold adequate and up to date information on clients’ beneficial ownership and conducts regular re-checks on clients and their activity.

5. Risk assessment

The Company applies a Risk Based Approach across the business, this requires identification, assessment, understanding and mitigation of AML/CTF risk including considering risk factors such as customer, product, geography and channel.