Sentvia Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

INDEX

1. Introduction to the Policy and Objectives
2. Definitions of Money Laundering and Terrorism Financing
3. Governance
4. Prevention Procedures
5. List of Applicable Laws, Regulations and International Legislation
6. Obligations
7. Compliance and Reporting
8. Commitment
9. Transaction Monitoring
10. Reporting of Suspicious Activity
11. Confidentiality of Information
12. External Reporting
13. Record Keeping
14. AML and CTF Training

1. Introduction to the Policy and Objectives

Sentvia (“Sentvia”) is a virtual asset service provider of payment, handling, and processing services of cryptocurrency and fiat. Sent takes a zero-tolerance approach to money laundering and terrorist financing activities and is committed to implementing and enforcing effective internal controls to counter such activities. It is the policy of Sentvia to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under local, national, and international laws and their implementing regulations. The goals of Sentvia's Money Laundering and Terrorism Financing Prevention Policy, its implementation procedures, and measures are regulated in this Policy. Our AML and CTF policies, procedures, and internal controls are designed to ensure compliance with all applicable acts of law of the Republic of Lithuania, local, and international legal acts; and will be reviewed and updated regularly to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

Our AML policy applies to all employees, directors, stakeholders as well as customers who have participated in the compulsory onboarding acceptance of this policy. By strictly adhering to this policy, we ensure that our services are not exploited for illicit activities and maintain the highest standards of integrity and compliance. The Policy applies globally throughout the Sentvia, aligning with pertinent global standards and international guidelines. Each legal entity within the Sentvia may supplement this Policy with appendices to detail the implementation of additional relevant local rules and regulations. All employees and Associated Persons of Sentvia, irrespective of their department or job role, including consultants and contractors, are required to comply with this Policy.

2. Definitions of Money Laundering and Terrorism Financing

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins and ownership of the proceeds from criminal activities, so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets, thereby avoiding prosecution, conviction, and confiscation of criminal funds. In Lithuania, money laundering is defined as the intentional act of:

• Converting or transferring property derived from criminal activity to conceal its origin.
• Concealing or disguising the true nature of property derived from criminal activity.
• Acquiring, possessing, or using property derived from criminal activity.
• Aiding and abetting in the commission of any of the above activities.

Terrorism Financing is the act of providing financial support to terrorist organizations or terrorists and involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations. Funds may stem from both legal and illicit sources.

Financing of Terrorism is when a person intentionally commits any of the following:

• Any acts abovementioned if they are aware that the proceeds are wholly or partly owned by an organization or person involved in acts of terrorism.
• Providing or collecting, preparing, or obtaining proceeds or facilitating their obtainment with the intent to use them or knowing that such proceeds will be used wholly or partly in an act of terrorism.

3. Governance

Sentvia has designated the Head of Compliance Policy & Governance as its Anti-Money Laundering Program Compliance Officer with full responsibility for Sentvia's AML Program. The Compliance Officer is responsible for the development of the above-mentioned Policy and its implementation at Sentvia.

The duties of the AML Compliance Officer will include monitoring Sentvia's compliance with AML obligations, overseeing communication and training for employees, and ensuring participation in the implementation of established prevention measures. The AML Compliance Officer will also ensure that the firm keeps and maintains all required AML records and that Suspicious Activity Reports (SARs) are filed with the relevant statutory authorities when appropriate. The AML Compliance Officer is vested with full responsibility and authority to enforce Sentvia's AML program.

4. Prevention Procedures

‍The main money laundering and terrorism financing prevention procedures are as follows:

• Know Your Customer procedures.
• Customer Identification.
• Monitoring of the financial transactions performed by Customers.
• Identification of suspicious transactions and termination thereof.
• Keeping of information about transactions performed by Customers.
• Providing timely information and training to Sentvia staff.
• Internal Controls.

5. List of Applicable Laws, Regulations, and International Legislation

‍This AML policy is in compliance with the following laws and international standards:

• Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania.
• Law on the Implementation of Economic and other International Sanctions of the Republic of Lithuania.
• Relevant resolutions of the Government of the Republic of Lithuania.
• 5th and 6th EU Anti-Money Laundering Directives (AMLD5 and AMLD6).
• Guidance from the Financial Crime Investigation Service (FCIS).
• The FATF Standards: FATF Recommendations (November 2023).
• FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021).

6. Obligations

‍Sentvia, along with its employees and Associated Persons, is obligated to comply with the Global Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy, as well as the laws and regulations that support it.

7. Compliance and Reporting

‍Failure to comply with this policy and any underlying procedures may result in personal liability, such as fines and imprisonment, as well as consequences within Sentvia itself, ranging from an internal warning up to and including employment termination for employees and termination of relationships for relevant third parties. In addition, it may expose Sentvia to civil and criminal liability, fines, reputational damage, operational risk, and other serious consequences.

Any circumvention of this policy is absolutely prohibited. Any deviation from this policy must be approved by the AML Compliance Officer and appropriately documented. Sentvia expects all employees and Associated Persons to report any violation or suspected violation of this policy, as well as suspected financial crime or potentially suspicious activity, to the Chief Legal Risk Compliance Officer (CLRCO) or the respective local Money Laundering Reporting Officer (MLRO). Material breaches, including but not limited to situations in which a regulatory requirement has not been met, must also be reported to the MLRO for further review.

8. Commitment

‍By fostering a culture of compliance and vigilance, Sentvia reinforces its commitment to upholding the highest standards of integrity and responsibility, to minimize risks to both individuals and the organization as a whole.

9. Transaction Monitoring

Acting in compliance with the international and national requirements regulating the prevention of money laundering and terrorist financing, Sentvia follows the Know Your Transaction (KYT) principle. Sentvia's requests to provide information should be considered as a routine process that applies to all customers.

Sentvia utilizes a multilayered transaction screening framework, a Transactions Monitoring Program called “Elliptic.” The program, based on a risk score analytic approach, screens for applicable red flags and assigns a risk score accordingly. The Compliance Team performs the necessary analysis of alerted accounts, including associated transactions, to determine if any unusual or suspicious activity is observed.

10. Reporting of Suspicious Activity

A suspicious activity can be defined as any action or activity which may result in the belief or knowledge that a customer is involved or planning to be involved in a crime or some other type of dishonest behavior. Sentvia requires all its employees, irrespective of their location, grade, or function, who know, suspect, or have reasonable grounds for knowing or suspecting that a person (whether a customer or an employee) is engaged in money laundering, terrorist financing, or another form of financial crime, to escalate the matter immediately to the Money Laundering Reporting Officer (MLRO). Failure to report will lead to serious consequences for the employee and Sentvia.

11. Confidentiality of Information

Employees must follow any instructions given to them regarding the disclosure they have made and must not make any further investigations themselves. Sentvia is prohibited from disclosing that it has escalated suspicious activity or that any report, internal or external, has been filed to any person except the MLRO. Violations of this principle may prejudice the investigation.

12. External Reporting

Following the escalation, the MLRO will evaluate the activity and determine if there are sufficient grounds to file an external report. Where sufficient grounds exist, the MLRO in the relevant jurisdiction will submit an external report to the local financial intelligence unit as soon as practically possible.

13. Record Keeping

A record will be kept of any internal reports submitted to the MLRO that have not been externally filed, including details of any action taken. Similarly, for all externally filed reports, Sentvia will keep records, including inquiries related to disclosures and any communication sent or received concerning the submitted report.

14. AML and CTF Training

Regular training on AML/CTF regulations and guidelines is an important aspect of identifying risks in this space. Training ensures a consistent approach to periodically assessing AML training needs, delivering, tracking, documenting, and reporting on training results.

Business managers, as the first line of defense, are primarily responsible for understanding and assessing key risks and ensuring the effective implementation and ongoing operation of internal controls. Compliance, as a second line of defense, provides independent oversight of adherence to AML laws and regulations.

The firm will take reasonable care to provide appropriate anti-money laundering training for its staff who handle, or are managerially responsible for, transactions that may involve money laundering.

Training will be conducted at the following frequencies:

• Induction training for all new joiners.
• Refresher training (at least annually) for all staff.
• Key revisions training (at every key revision impacting AML operations).