Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Applicable to international token buyers during the PreSale phase

1. Introduction & Scope

This policy serves to implement international and European directives to combat money laundering (AML) and terrorist financing in connection with the purchase of our tokens. It applies to all natural and legal persons intending to participate in the token sale.

2. Legal Basis

This policy is based on:

EU Directive (EU) 2015/849 (AMLD4) and (EU) 2018/843 (AMLD5),
The 6th EU Anti-Money Laundering Directive (EU) 2018/1673 (AMLD6),
As well as local AML regulations depending on the buyer’s place of residence.

3. Identity Verification Requirement (KYC)

Each buyer must verify their identity before being allowed to purchase tokens. The following steps are mandatory:

For individuals:

Full name, date of birth, residential address
Upload of a valid ID document (passport, national ID card)
Proof of address (e.g., utility bill, bank statement, less than 3 months old)
Optional: Selfie holding the ID document

For companies:

Commercial register excerpt
Proof of beneficial ownership (UBO)
ID of the managing director
Articles of association or founding documents

4. Source of Funds

For investments of €10,000 or more, the following is additionally required:

Proof of source of funds (e.g., payslips, bank statements, sales contracts, tax assessments)
Declaration of financial background
Enhanced due diligence in case of suspicious indicators

5. Automated Checks & Wallet Screening

We use automated screening tools to compare wallet addresses against known sanction lists (OFAC, UN, EU), darknet transactions, or other high-risk factors. Wallets with suspicious transaction behavior may be excluded from the token sale.

6. Data Storage & Privacy

All data will be stored for at least 5 years after the end of the business relationship.
Data is stored in encrypted form on servers within the EU.
Buyers may request information about the stored data at any time (in accordance with the GDPR).

7. Reporting of Suspicious Activities

Suspicious cases will be reported immediately to the national Financial Intelligence Unit (FIU).
Purchases may be blocked without prior notice if suspicion arises.
There is no legal entitlement to participate in the token sale.

8. Responsible Officer (MLRO)

An internal compliance officer (Money Laundering Reporting Officer – MLRO) is responsible for:

Implementing and monitoring AML procedures
Coordination with external service providers (e.g., Onfido, SumSub)
Cooperation with law enforcement authorities

9. International Investors

Investors from countries with high AML risk (according to the FATF list) are excluded from purchasing tokens. These include, among others:

Syria, Iran, North Korea, Afghanistan, etc.
Buyers from certain countries may be subject to additional checks or require special approvals.

10. Changes to the Policy

This policy may be updated at any time. Changes take effect upon publication on the website.