1. General provisions

1.1. This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as "AML/KYC Policy") sets out the principles and measures that the 1ADK platform (hereinafter referred to as the "Platform") uses to identify, prevent, and minimize the risks of its services being used for unlawful purposes.

1.2. The Platform is managed by the limited liability company SIA "FinMV", registered in accordance with the legislation of the Republic of Latvia (registration number: 40203378371, legal address: Vesetas iela 10–95, Rīga, LV-1013, Republic of Latvia) (hereinafter - "Company").

1.3. This Policy is developed in accordance with the requirements of: Directives of the European Union in the field of AML/CTF; the Law of the Republic of Latvia "On the Prevention of Money Laundering and Terrorism Financing"; Recommendations of FATF (Financial Action Task Force); other international and national regulatory acts regulating AML/KYC.

2. Goals and objectives of Politics

2.1. The main goals of this Policy are: preventing the use of the Platform for money laundering or terrorist financing; protecting the reputation of the Company and Clients; ensuring transparency and legality of financial transactions.

2.2. To achieve these goals, the Company implements a set of measures, including customer identification and verification (KYC), transaction monitoring, and interaction with competent authorities.

3. Client Identification and Verification (KYC)

3.1. When registering, the Client must provide: full legal name (for legal entities) or surname, first name, and patronymic (for individuals); registration number and legal address (for companies); email address used for communication; country of residence.

3.2. For Clients purchasing Enterprise or Market Maker category tariffs, the Company may request additional documents, including: founding documents and licenses; information about beneficial owners; confirmation of the sources of funds.

3.3. The company reserves the right to refuse to provide services to customers who have refused to undergo the KYC procedure.

4. Monitoring and verification

4.1. The company conducts regular monitoring of clients' activities to detect suspicious transactions.

4.2. Signs of suspicious transactions include: attempting to register using false or fictitious information; payment for services from anonymous or questionable sources (for example, from third parties without explanation); signs of Clients using the Platform from jurisdictions with a high level of risk (offshore zones, sanctioned countries, countries with a high level of corruption).

4.3. In case of detecting suspicious activities, the Company has the right to suspend the provision of services to the Client until the circumstances are clarified and to request additional documents.

5. Prohibited clients and jurisdictions

5.1. The company does not enter into contracts and does not provide services to: individuals and organizations included in the sanction lists of the EU, OFAC, UN, and the UK; legal entities registered in countries with a high level of AML risk (FATF "High-Risk Jurisdictions" list); individuals whose activities are related to industries at high risk of money laundering (gambling, illegal trade, trafficking of narcotics and weapons).

6. Clients' responsibilities

6.1. Clients undertake to provide only accurate information and documents for KYC procedures.

6.2. Clients are fully responsible for any violation of AML/KYC legislation related to their own activities and the use of Leads.

7. Interaction with government authorities

7.1. The company undertakes to cooperate with supervisory and law enforcement authorities of the Republic of Latvia and the European Union in accordance with the current legislation.

7.2. In cases of detecting suspicious transactions, the Company has the right to suspend the provision of services and send relevant information to the competent authorities.

8. Responsibility

8.1. The client is responsible for any consequences caused by providing false information or using the Platform for purposes that violate AML/KYC requirements.

8.2. The company reserves the right to refuse to provide services or terminate the contract with the Client in case of violation of this Policy.

9. Final provisions

9.1. This Policy shall enter into force upon its publication on the Platform.

9.2. The company reserves the right to unilaterally change this Policy.

9.3. The current version of the Policy is published on the Platform and is mandatory for all Clients.