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Customer Identification Procedure (CIP)

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Documentation

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Anti-Money Laundering Compliance Officer

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Transaction Monitoring

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Cooperation with Law Enforcement

CIP applies to transactions that our assessment system deems suspicious. We collect certain identification information about each client who undergoes CIP.

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Request for identification data;

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Full name;

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Date of birth (for individuals);

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Residential address (for individuals) or principal place of business, office, or other physical location;

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For individuals only – a valid government-issued ID confirming citizenship or residence and having a photograph, such as a driver's license or passport;

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For legal entities – documents confirming the existence of a legal entity, such as a certified charter, business license, partnership agreement, or other verifying document;

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Verification of the received information for originality and accuracy. The client must ensure that the information provided is accurate, complete, and timely updated. If there are grounds to believe that the information provided by the client is incorrect, false, outdated, or incomplete, we reserve the right to send the client a notice requiring correction and supplementation of identification information. Depending on the circumstances, Ebitok may blacklist an existing account and terminate services for that client.

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Verification of information. We will continue verification based on the collected information to determine the true identity of our clients, using procedures based on the risk assessment of our service provider Sum & Substance Ltd, verifying the completeness and accuracy of the received information for client identification. A check is also carried out for the presence of the client in lists of citizens related to criminal activity and other lists of persons subject to sanctions. We will verify the information within a reasonable time, depending on the nature of the account and the level of transaction risk. We may request additional time for verification, limiting transactions and the client's account. If we discover suspicious information indicating possible money laundering, terrorist financing, or other suspicious activity, we may file a report in the form of SAR/STR in accordance with the legislative framework.

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Client notification We notify clients that their transactions may be subject to AML/KYC checks. This information is detailed in our Terms of Use, and each client is required to familiarize themselves with these Terms before starting transactions.

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Checks performed by third parties We may rely on CIP checks performed by an exchange or trading platform for any client, in case of the reasonableness of this decision by the exchange or trading platform. In this case, the client is also notified of the circumstances of this kind.

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We will document our verification, including all identifying information provided by the client, the methods used, and the results of the verification, as well as the resolution of any discrepancies identified during the verification process.

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According to Sum Substance documentation, all client data obtained during the KYC procedure is encrypted and stored on Amazon servers, in accordance with GDPR regulations, located in the European zone.

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All documentation may be provided to competent authorities upon request.

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The Anti-Money Laundering Compliance Officer is an authorized Ebitok employee responsible for implementing and effectively monitoring the application of the AML/KYC policy. The AML Compliance Officer monitors and modernizes all aspects of Ebitok's anti-money laundering and terrorist financing activities.

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Contact with the Anti-Money Laundering Compliance Officer regarding this Policy is carried out through [email protected]

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Ongoing monitoring is an important element of effective KYC procedures. It allows us to distinguish between normal client activity and suspicious activity that requires attention.

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We receive and store information about senders and recipients when exchanging crypto assets and provide it to the relevant authorities upon official request.