The purpose of the Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy of
EX GROUP s.r.o., registered at Školská 689/20, Nové Město, 110 00 Praha 1, Czech Republic, Registration Number: 21719420, is to identify, prevent, and mitigate the risks of the company being involved in or used for illegal activities.
Financial institutions and related entities, including cryptocurrency service providers, are frequently exposed to attempts of money laundering and terrorist financing. Anti-Money Laundering refers to the laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income. Terrorist financing is understood as the provision or collection of funds intended to support individuals or groups involved in terrorist activities, including fundraising, possession, use, or arrangement of such funds.
EX GROUP s.r.o. pays close attention to any activities that may be associated with money laundering or terrorist financing. In order to comply with applicable laws of the Czech Republic, international standards, and the requirements of MiCA, the company has implemented internal policies and procedures designed to prevent and detect money laundering, terrorist financing, drug trafficking, human trafficking, proliferation of weapons of mass destruction, corruption, and bribery, and to take appropriate action in case of any suspicious activity conducted by its clients. The company applies customer identification procedures, risk assessment, risk categorization, continuous monitoring of customer activity, and reporting to the competent authorities where required.
A designated Compliance Officer is responsible for the implementation and enforcement of this AML/CTF Policy and ensures that all relevant procedures are properly applied and maintained.
Before any customer is granted access to the services of EX GROUP s.r.o., the customer must complete a verification process. In accordance with legal requirements, the company is obligated to collect, verify, and retain information identifying each individual or legal entity that intends to use its services. Customers are required to provide personal information such as their full name, residential address, date of birth, and, where applicable, information about their organization and related persons. Where a customer is considered to present a higher level of risk, enhanced due diligence may be applied, including the request for additional information and documentation, which may extend the verification process.
EX GROUP s.r.o. reserves the right to carry out ongoing verification of customer identity, particularly where identification data has changed or where customer activity appears unusual or suspicious. The company may request updated documents from customers even if such documents have been previously verified. All customer information is collected, stored, processed, and protected in accordance with applicable data protection laws and the company’s Privacy Policy.
In order to fulfill its AML/CTF obligations, EX GROUP s.r.o. applies a risk-based approach, allowing the company to identify, assess, and understand the risks of money laundering and terrorist financing to which it may be exposed, and to apply appropriate mitigation measures proportionate to the level of risk identified.
Risk assessment includes factors related to customers and jurisdictions. Customer-related risks may arise from inconsistencies in identification documents, the use of forged, stolen, or invalid documents, fictitious identities, lack of reliable contact information, previous involvement in financial crime, links to terrorist activities, or discrepancies in documentation provided by legal entities. Politically exposed persons are also considered higher-risk customers, including individuals who hold or have held prominent public functions, such as heads of state or government, senior politicians, members of parliament, senior members of judicial bodies, executives of state-owned enterprises, diplomats, high-ranking military officials, and representatives of international organizations.
Jurisdictional risks are also taken into account, particularly in relation to countries identified as high-risk under applicable regulations. In such cases, enhanced due diligence measures may be applied, including obtaining additional information about the customer and beneficial owner, verifying the source of funds and wealth, understanding the purpose of transactions, and obtaining approval from senior management before establishing or continuing a business relationship.
EX GROUP s.r.o. conducts ongoing monitoring of customer activity in order to detect and prevent fraudulent, illegal, or otherwise suspicious behavior. All transactions are subject to review, and any activity that appears unusual or suspicious is carefully analyzed. Where necessary, the company may request additional information or documentation from the customer, suspend transactions, restrict access to services, or terminate the business relationship. If there are reasonable grounds to suspect involvement in illegal activity, the company will take appropriate action to prevent further misuse of its services.
In accordance with this Policy and applicable legal requirements,
EX GROUP s.r.o. will report any activities that may be related to money laundering or terrorist financing to the relevant competent authorities. The company does not disclose to customers whether such reports have been made and does not provide any information or commentary regarding such reporting.