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META PROJECTS UAB (hereinafter – the “Company”) is a virtual currency exchange and depository wallet operator, acting according to the laws of the Republic of Lithuania. The Company is committed to conduct business operations in a transparent and open manner consistent with its regulatory obligations.

1. TERMS AND DEFINITIONS

1.1. “Money laundering” or “ML” means the doing of any act which constitutes an offence of money laundering under the Criminal Code of the Republic of Lithuania and is defined in the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania. The criminal acts cover all procedures that seek tzo change the identity of illegally obtained funds, arising from drug dealing, terrorist activities or any other crime in order to give impression that such money originated from legitimate or legal sources. Money laundering is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, for example, fraud, corruption, organized crime, or terrorism etc. Predicate offences for money laundering are defined by the Criminal Code of the Republic of Lithuania.
1.2. “Terrorist financing” or “TF” means the provision of funds, directly or indirectly, with the intention that they should be used or in knowledge that they are to be used in order to carry out any of the offences within the meaning of Articles 1-4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism (as amended by Framework Decision 2008/919/JHA of 28 November 2008) and falling under Articles 250, 2501 – 2506 of the Criminal Code of the Republic of Lithuania.
1.3. “Company” means META PROJECTS UAB. The term “Company” when used in these Procedures also refers to the management bodies of the Company and the members of such bodies as well as the employees of the Company.
1.4. “Employee of the Company” or “Employee” means any natural person who is employed by the Company on the basis of employment agreement or other agreement. The term “Employee” when used in these Procedures also refers to the management bodies of the Company and the members of such bodies, unless the context requires otherwise.
1.5. “Client” means a person that uses services provided by the Company.
1.6. “Beneficial owner” means a natural person who ultimately owns or controls the Client or a natural person on whose behalf a Transaction is being conducted or the Monetary operations is being executed.
The Beneficial owner is:
• a natural person who ultimately owns or controls a legal entity through direct or indirect ownership or control over a sufficient percentage of the shares or voting rights in that legal entity, including through bearer share holdings (a percentage of 25% plus one share shall be deemed sufficient to meet this criterion), save a company listed on a regulated market that is subject to disclosure requirements consistent with the legislation of the European Union or subject to equivalent international standards;
• a natural person who otherwise exercises control over the management of a corporate entity;
• as regards legal entity which administers and distributes funds:
a natural person who is the beneficial owner of 25% or more of the property of a legal entity
(where the future beneficial owners have already been determined); where the individuals that benefit from this legal entity have not yet been determined, the class of persons in whose main interest the legal entity is set up or operates;
• a natural person who exercises control over 25% or more of the property of the legal entity.
1.7. “Business relationship” means a business, professional or commercial relationship of the Company with a Client that is expected, at the time when entering in such relationship, to have an element of duration.
1.8. “Transaction” means a contractual arrangement between the Company and the Client on the provision of the virtual currencyservices.
1.9. “Monetary operation” means any payment, transfer or receipt of funds executed by the Company under the instructions of a Client, save the payments to state and municipal institutions, other budgetary institutions, the Bank of Lithuania, state or municipal funds, diplomatic missions or consular posts of foreign countries or settlement with these institutions.
1.10. “Suspicious Monetary operation or Transaction” means a Monetary operation or Transaction which relates to either the funds derived from the illegal activities or the funds obtained in the course of the illegal activities or the terrorist financing and which meets at least one of the criteria established by the Order of the Director of the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania No V-240 of 5 December 2014 as described in details in Section 7 below.
1.11. “Politically exposed natural person” or “PEP” means a natural person who is or has been entrusted with prominent public functions and immediate family members or persons known to be close associates of such person. A person is considered to be a PEP for a period of 1 year after ceasing to be entrusted with the Prominent public functions.
1.12. “Prominent public functions” means functions within the Lithuanian, European Union, international or foreign public authorities:
(1) the head of the State, the head of the government, a minister, a vice-minister or a deputy
minister, a secretary of the State, a chancellor of the parliament, government or a ministry;
(2) a member of the parliament;
(3) a member of the Supreme Court, the Constitutional Court or any other supreme judicial authorities whose decisions are not subject to appeal;
(4) a mayor of the municipality, a head of the municipal administration;
(5) a member of the management body of the supreme institution of state audit or control, or a chair, deputy chair or a member of the board of the central bank;
(6) an ambassador, a chargé d’affaires ad interim, a special envoy and a minister plenipotentiary or a high-ranking military officer;
(7) a member of the management or supervisory body of a public undertaking, a public limited company or a private limited company, whose shares or part of shares, carrying more than 1/2 of the total votes at the general meeting of shareholders of such companies, are owned by the State;
(8) a member of the management or supervisory body of a municipal undertaking, a public limited company or a private limited company whose shares or part of shares, carrying more than 1/2 of the total votes at the general meeting of shareholders of such companies, are owned by the State, and which are considered as large enterprises in terms of the Law of the Republic of Lithuania on Financial Statements of Entities;
(9) a director, a deputy director or a member of the management or supervisory body of an international intergovernmental organisation;
(10) a leader, a deputy leader or a member of the management body of a political party.
1.13. “Close associate” means a natural person who:
(1) participates in the same legal entity or maintains other business relationships with a person who performs or previously performed the prominent public functions;
(2) is the sole owner of the legal entity set up or operating de facto with the aim of acquiring property or another personal benefit for a person who performs or previously performed the prominent public functions.
1.14. “Close family member” means spouse, person in registered partnership (cohabitant), parent, brother, sister, child and child’s spouse or child’s cohabitant.
1.15. “Financial institution” means the credit institutions and financial undertakings as defined in the Law of the Republic of Lithuania on Financial Institutions, payment institutions as defined in the Law of the Republic of Lithuania on Payment Institutions, electronic money institutions as defined in the Law of the Republic of Lithuania on Electronic Money and Electronic Money Institutions, operators of currency exchange offices as defined in the Law of the Republic of Lithuania on Currency Exchange Operators, operators of crowdfunding platforms as defined in the Law of the Republic of Lithuania on Crowdfunding, operators of peer-to-peer lending platforms as defined in the Law of the Republic of Lithuania on Consumer Credit and the Law of the Republic of Lithuania on Credit Relating to Immovable Property, insurance undertakings engaged in life insurance activities and insurance brokerage firms engaged in insurance mediation activities relating to life insurance as defined in the Law of the Republic of Lithuania on Insurance as well as investment companies with variable capital and collective investment undertakings intended for informed investors and management companies managing only those undertakings; branches of these foreign financial institutions set up in the Republic of Lithuania as well as electronic money institutions and payment institutions whose registered office is in another European Union Member State providing services in the Republic of Lithuania through agents, natural or legal persons.
1.16. “European Union Member State” or “EU Member State” means a state which is a Member State of the European Union (“EU”) or a state of the European Economic Area (“EEA”).
1.17. “Third party” means a Financial institution or another entity as defined in the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania as well as a financial institution or another entity registered in another EEA Member State or a state which is not a EEA Member State (third country), who meets the following requirements:
(1) they are subject to mandatory professional registration, recognised by law;
(2) they are registered in a EU Member State or in a third country which applies requirements that are equivalent to the EU identification requirements and record keeping requirements in respect of Clients and Beneficial owners, and which is monitored by the competent authorities in terms of the compliance with the said requirements.
1.18. “Other than FATF country” means (i) a country that is not a member of the Financial Action Task Force (“FATF”) on Money Laundering or of an international organization with an observer status at
FATF that participates in the efforts to combat money laundering and terrorist financing and (ii) considered to be High-risk and non-cooperative jurisdiction. The list of the countries other than FATF countries is provided under the following link: http://www.fatf-gafi.org/countries/#high-risk.
1.19. “Target territory” means a foreign state or zone as specified in the Law on Corporate Income Tax of the Republic of Lithuania. The list of the target territories is attached to these Procedures as Annex Four.
1.20. “Financial intelligence unit” or “FIU” means the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania.
1.21. “Money laundering reporting officer” or “Officer” means an employee of the Company who is appointed by the managing director of the Company as the officer responsible for the ML and TF prevention in the Company.
1.22. “Procedures” means these procedures on the prevention of money laundering and terrorist financing and all its annexes as may be further amended from time to time.
“Register ” means all and any
electronic register
which the Company keeps:1. Log of Submitted SARs To be kept for 8 years after terminating business relationship
2. Log of virtual currency exchange and transactions equal or greater than EUR 15 000 or currency/virtual currency equivalent
3. Log of all customer transactions
4. Log of business relationships terminated due to ML/TF reasons
5. Copies of ID documents, identification information and KYC information
6. Digital currency wallet address together with owner’s identity information
7. Correspondence with customer To be kept for 5 years after terminating business relationship
8. Supporting documents obtained from customer To be kept for 8 years after completing transaction
9. Internal investigation records of suspicious transactions To be kept for 5 years
10. Other records To be kept for 8 years

Other records:
· evidence of the training programs on money laundering/terrorism financing prevention whether inhouse or external;
· other records if required under the AML law of Lithuania as well as other legal acts related to the prevention of money laundering/terrorism financing;
2. ROLES AND RESPONSIBILITIES

2.1. The Board has a critical oversight role – as the senior-most management of the company, they should approve and oversee policies for risk, risk management and compliance. The Board also should have a clear understanding of the ML risks, including timely, complete, and accurate information related to the risk assessment to make informed decisions. Along with the General manager, the Board should appoint a qualified AML Officer with overall responsibility for the AML function and provide this seniorlevel officer with sufficient authority that when issues are raised they get the appropriate attention from the Board, the General manager and the business lines. The Board is responsible for the overall AML/CTF compliance policy of the Company and ensuring adequate resources are provided for the proper training of staff and the implementing of risk systems. The Board will receive and consider quarterly compliance reports presented by the AML Officer.
2.2. The General Manager will receive and consider the monthly compliance reports sent by the AML Officer and authorize changes based on the recommendations if required. General Manager will also receive reports on particularly significant changes that may present risk to the organization. Assistance may be given to the AML Officer in the preparation of the AML program.
2.3. The Compliance Officer (AML Officer) is responsible for managing compliance risks, developing company’s policies and procedures, and monitoring compliance issues. The AML Officer is responsible for reporting significant changes that may present high ML/TF risks to the Company. The AML Officer prepares monthly and quarterly reports for consideration to the General Manager and the Board and conducts risk assessments of compliance systems, develops regular random analysis. The AML Officer establishes and implements the risk scoring matrix following regulatory guidance and for review and approval by the General Manager.
2.4. The MLR Officer (MLRO) is responsible for Transaction monitoring, receiving internal disclosures and making reports to the Financial Crime Investigation Service (FCIS). First point of contact for all compliance issues from staff. MLRO undertakes regular random analysis of transactions including assessment of documentary evidence provided by Clients and prepares any necessary amendments to the Policy in line with risk assessment. MLRO ensures everyone is periodically informed of any changes in anti-money laundering and anti-terrorist financing legislation, policies and procedures, as well as current developments and changes in money laundering or terrorist activity financing schemes particular to their jobs, constructing AML/CTF-related content for staff training programs. Independently from front office staff, MLRO reviews Client identification information to ensure that all the necessary information has been obtained.
2.5. Other staff members are responsible familiarize with this Policy, other internal procedures related to their job role and understanding responsibilities. Ensure AML/CTF procedures are adhered to. Ensure that all suspicious activity is reported to the AML Officer.

3. PROCEDURES TO FOLLOW

3.1. While complying with the legal procedures and implementing the ML/TF prevention measures, Employees depending on their position and functions within the Company must comply with the following procedures described in details further in these Procedures:
(1) Procedure of AML trainings;
(2) Procedure of reporting;
(3) Procedure of identification of customers;
(4) Procedure of monitoring;
(5) Procedure of business wide risk assessment;
(6) Procedure of implementation of international sanctions;

4. KYC PROCEDURES (CLIENT DUE DILIGENCE)

4.1. Client Due Diligence (“due diligence” or “CDD”) process must comply with procedures as detailed herein. These include the identification of the Client, ML/TF risk assessment, assessment of the financial position of the Client, validity of identity and the source of funds.
4.2. The following procedures which constitute the ML/TF prevention measures shall be carried out in order
to perform customer due diligence at inception of a Business relationship with a Client:
(1) identification of persons who apply to the Company as the potential Clients;
(2) verification if the potential Clients acts as a principal; if the potential Clients is represented by other person (agent), the identification and verification of the representative (agent) applies as well;
(3) identification and verification of the identity of the Beneficial owner, if applicable;
(4) identification of the identity of the Client’s director (Full name, date of birth or personal code, nationality), if applicable;
(5) obtaining information on the Client’s management structure and the nature of its activity, if applicable;
(6) obtaining information on purpose and intended nature of the relationship with the Company; the above steps are essential prior to initiation of a Business relationship with the potential Client and after the Client is engaged in the Business relationship, the following ML/TF prevention measure must be taken:
(7) ongoing monitoring of the Business relationship with the Client and the Monetary operations and Transactions of the Client.
4.3. The Client can be turned away before a Business relationship is formed, during the due diligence process or the stages following acceptance of a Business relationship.

5. IDENTIFICATION OF THE CLIENTS, THE BENEFICIAL OWNERS AND THE REPRESENTATIVES OF THE CLIENTS (WHERE APPLICABLE)

5.1. The Company requires a good working knowledge of the Client’s activities in order to provide an effective service, including evidence of their identity. The Company needs to identify the Clients, their Beneficial owners (where applicable) and the representatives (where applicable) in the following circumstances:
(1) prior to establishing business relationship. The creation of a deposit wallet of virtual currencies is not a business relationship if no more than one transaction, operation, deposit or withdrawal has taken place in that wallet within six months and the amount is less than EUR 1 000 or currency/ virtual currency equivalent; (2) before:
• executing occasional virtual currency exchange transactions or operations in virtual currency with funds equal to or above EUR 1,000 or currency/virtual currency equivalent;
• occasional depositing or withdrawing of virtual currency amounting to or above EUR 1,000 or currency/virtual currency equivalent;;
• transaction is carried out in one or more interrelated transactions (the
value of the virtual currency being determined at the time of the monetary transaction or operation) unless the customer and beneficial owner have already been identified.
• when there are doubts about the veracity or adequacy of previously obtained identification data of the Client and/or the Beneficial owner and/or the representative of the Client (where applicable);
• in any other case when there are suspicions that the act of ML or TF is, was or will be performed.
5.2. The identification evidence must be obtained before the provision of any services to a prospective Client or an established Client – if sufficient evidence cannot be obtained the Company must not proceed with the business. The more detailed identification requirements are provided in Annex Two to these procedures.

6. IDENTIFICATION METHODS

6.1. Clients may be identified by face-to-face contact, or using non-face-to-face identification methods. This also applies to those cases where the Client, either natural or legal person, is represented by another person.
6.2. When identifying Clients by face-to-face contact, the Client must provide an original personal identification document – for natural persons; or the registration and/or other corporate documents – for legal persons. More detailed requirements on face-to-face identification are provided in Annex Two.
6.3. The non-face-to-face identification can be executed:
6.3.1. When information about Client’s identity is certified by his qualified electronic signature which complies with the requirements of Regulation (EU) No 910/2014.
6.3.2. When information about Client’s identity is confirmed by electronic identification means issued in the European Union and functioning under electronic identification schemes with high or substantial assurance level under Regulation (EU) No 910/2014.
6.3.3. Using electronic means, allowing direct view transmission, in one of the following ways:
(a) identity document issued by the government body is captured using video-streaming and identity is confirmed using at least an advanced electronic signature, meeting the requirements referred to in Article 26 of Regulation (EU) No 910/2014;
(b) Client’s facial image and original identity document issued by the government body are captured using video-streaming.
6.3.4. Using the Third party information on the Client or the Beneficial owner;
6.3.5. Before commencing the use of the services of the Company, a payment order is made to the payment account of the above institution from the account held on behalf of the Client in the credit institution which is registered in the EU Member State or in a third country which applies the requirements equivalent to those specified in the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania and which is monitored by competent authorities as to the compliance with such requirements, and a paper copy of the identification document, which is approved in the manner prescribed by legal acts of the Republic of Lithuania, is submitted.
6.4. The more detailed information and technical requirements for non-face-to-face identification methods are provided in Annex Three.

7. RISK ASSESSMENT

7.1. An important aspect of the due diligence process is the assessment of the risks involved and the acceptability of a prospective Client. Before agreeing to provide a service to a prospective Client, an assessment of the risks involved should be completed. This involves assessing the acceptability as a Client and the risk associated with the particular services requested by the Client. This on-going evaluation is necessary to consider relevant issues before deciding as to whether the required services should be provided.
7.2. When entering into the Business relationship with the Client, the ML/TF risk is assessed on the basis of the documentation and information obtained from a prospective Client. Special attention must be given to the behaviour of and the verbal communication with a prospective Client as well as the criteria of the High Risk Clients and Low Risk Clients as listed in Sections 9 and 10 below. When assessing the ML/TF risk the aim is to establish and assess the following circumstances:
(1) type of the Client, i.e. whether a prospective Client meets the profile of the typical client of the Company; if not, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; the special attention is given to the following circumstances which may increase the ML/TF risk: a. if the Client is a PEP;
b. where the prospective Client is a non-profit institution (“NPI”);
c. other circumstances indicated in these Procedures;
(2) commercial relationships, i.e. assessing if the behaviour of a prospective Client reveals that the
aims and duration of the relationship expected by a prospective Client may considerably differ from what is inherent to the profile of the typical Client of the Company; if yes, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; in addition it needs to be established if the Client acts as a principal or is represented by the third person (agent);
(3) product, i.e. assessing if the virtual currency exchange and wallet services in which a prospective Client is interested correspond the nature of the business and the Transaction profile of such prospective Client; if not, the additional clarification and/or documentation must be requested from the Client seeking to establish if there is a high ML/TF risk; attention should be drawn where the Client or the potential Client is to transact in new or developing technologies which may give rise to a threat of ML/TF or the use of Monetary operations or Transactions that might favour anonymity;
(4) territory, i.e. assessing where the main place of interests of a prospective Client is situated, e.g. where the Client is living/incorporated or where the place of the main business activity of the Client is situated or where the main part of the customers of the Client comes from; it is important to establish if such main place of interests of the Client is situated in the country other than FATF country or in the Target territory; in such event the Client has to be considered as a high risk client.
7.3. The following circumstances shall indicate a high risk and accordingly trigger high risk due diligence level:
(1) a prospective Client starts to expresses his interest in the topics related to ML/TF;
(2) a prospective Client is reluctant to perform the actions necessary for identification and to provide information related to the Client and its financial activity;
(3) a prospective Client refuses to provide documents or information requested by the Employee or non-face-to-face identification measures for the identification purposes, especially information/documentation evidencing the financial activity of the Client;
(4) the doubts regarding the correctness or authenticity of the documents or information provided by a prospective Client arises;
(5) a prospective Client is not able to answer the questions provided by the Employee or by non-faceto-face identification measures and related to the financial activity of the potential Client, the nature and the aims of such activity;
(6) a prospective Client is unusually stressed and nervous during the verbal communication with the Employee, especially when asked the questions related to the financial activity of a prospective Client.
7.4. The Officer has to assess the above circumstances, indicated in Point 7.2 and 7.3 above, and decide whether to refuse accepting the Business relationship with such potential Client or, if decided to further proceed with the due diligence procedure, the enhanced due diligence has to be applied.
7.5. After the risk assessment is performed the Client is assigned to one of three categories according to its risk profile:
(1) Average Risk Clients who do not qualify as the High Risk Clients or Low Risk Clients – the standard due diligence and ML/TF prevention measures apply;
(2) High Risk Clients who are defined in Section 9 below – the enhanced due diligence and ML/TF prevention measures apply;
(3) Low Risk Clients who are defined in Section 10 below – the simplified due diligence and ML/TF prevention measures may apply.
7.6. The profile of the Client is reviewed periodically (at least once a year) reflecting the changes in the Business relationship and behaviour of the Client as well as based on the results of the ongoing monitoring of the Client. Thus, the risk profile and, accordingly, the ML/TF prevention measures applied with respect of the Client may change from time to time.
7.7. The Company must ensure that all risk assessment documentation as well as the results of the risk assessment and all changes to the risk profile of the Client are available in the Company’s records (i.e. data base) and may be made available for the future needs or if required by the relevant authorities.

8. ADDITIONAL SOURCES

8.1. In addition to the information and documentation provided by or on behalf of the Client and obtained from the Third parties (where relevant), the Company has to check the below sources if the provided information is correct or to establish the missing information regarding the Client:
(1) SDN list. List of specially designated nationals and blocked persons. SDN list is a publication of OFAC which lists individuals and organizations with whom United States citizens and permanent residents are prohibited from doing business.
https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx
(2) EU sanctions list. Consolidated list, containing the names and identification details of all persons, groups and entities targeted by financial restrictions.
https://eeas.europa.eu/headquarters/headquarters-homepage/8442/consolidated-listsanctions_en
8.2. The sources which the Company applies with regard to the particular Clients may differ depending on the circumstances of each particular case. The Company must ensure that all results of such searches are available in the Company’s records and may be made available for the future needs or if required by the relevant authorities.
8.3. The requirement to double check the provided information by the Client may not be followed when the Client is the Financial institution.

9. ENHANCED DUE DILIGENCE PROCEDURES

The Company applies the enhanced due diligence procedures in the following instances:

9.1. High Risk Clients

9.1.1. All High Risk Clients must be subject to the application of enhanced due diligence measures. For instance, PEPs and the Clients from the high risk territories are considered to pose a higher risk of ML/TF and automatically require the application of enhanced due diligence and ongoing monitoring.
9.1.2. High Risk Clients are also those Clients who are assigned to this category after the risk assessment or due to the results of the ongoing monitoring, e.g. the High Risk Clients are as follows:
(a) those who do not correspond to the profile of the typical Client of the Company significantly and after carrying an additional investigation the Employee decided that the Client or its activity raises high ML/TF risk;
(b) those whose behaviour during the due diligence procedure was suspicious and, therefore, reported to the Officer (Section 7 above) who after carrying an additional investigation decided to proceed further with the enhanced due diligence procedure;
(c) whose commercial relationship or behaviour during the due diligence procedure were unusual and after carrying an additional investigation it is decided that the Client or its activity raises high ML/TF risk;
(d) the Client performs non-cash transfer operations on the request of persons not related to the main activity of the Client;
(e) the Client is from a high-risk third country identified by the European Commision.
(f) the permanent place of residence of the Client – natural person (where applicable) is a territory other than FATF country;
(g) the Client – legal person or another organization is registered in a Target territory;
(h) the main place of the interests of the Client is situated in the country other than FATF country or in the Target territory;
(i) the checks in the additional sources as listed in Section 8above reveals that the data of the Client, its representative (where applicable) or the Beneficial owner conform to the data of the persons associated with the ML/TF as specified in the respective lists of the Republic of Lithuania, EU, FATF or the United Nations;
(j) the checks in the additional sources as listed in Section 7 above reveals that the data of the Client, its representative or the Beneficial owner (where applicable) conform to the data of the persons under the financial sanctions in accordance with the Law on Implementation of Economic and other International Sanctions of the Republic of Lithuania;
(k) the unusual behaviour of the Client is established that does not correspond to the ordinary course of activities of the Client (e.g. increasing amounts of payments, especially to the payees or for the goods or services that do not correspond the declared activity of the Client);
(l) those who were assigned to the category of the High Risk Client due to other reasons that raises high ML/TF risk of the Client.

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