PIXTUB UAB AML POLICY

The PIXTUB Anti-Money Laundering and Know Your Customer Policy (hereinafter - the "AML/KYC Policy") is designed to prevent and address potential risks associated with illegal activities. Both international and local regulations mandate PIXTUB to establish robust internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, as well as corruption and bribery. The AML/KYC policy encompasses the following areas:
1. Verification procedures
2. Specific EDD Measures
3. Sanctions and PEP lists screening
4. Employee Training
5. Compliance Officer
6. Transaction Monitoring
7. Risk assessment
8. Periodic Review and Updates
9. Record Keeping

1.Verification procedures
Customer Due Diligence (CDD) is a global standard aimed at preventing illegal activities. In alignment with CDD, PIXTUB enforces its own verification processes, adhering to anti-money laundering regulations and Know Your Customer (KYC) frameworks.

1.1 Identity verification

PIXTUB mandates that users submit reliable and independent documents, data, or information (such as a national ID, international passport, driver's license, bank statement, or utility bill) for identity verification, in line with its AML/KYC Policy. PIXTUB retains the right to gather this identification information from users.
To verify the authenticity of the submitted documents and information, PIXTUB will use all legal methods available. Furthermore, PIXTUB reserves the right to investigate users who are considered risky or suspicious.
PIXTUB may conduct ongoing identity verification, especially if there are changes in identification information or if a user's activities appear suspicious or unusual for them. Additionally, PIXTUB reserves the right to request updated documents from users, even if they have previously passed identity verification.
User identification information will be collected, stored, shared, and protected in strict accordance with PIXTUB’s Privacy Policy and relevant regulations.
By confirming a user’s identity, PIXTUB can reduce potential legal liabilities if its services are used for illegal activities.

1.2 Card verification

Users wishing to use payment cards with PIXTUB's services are required to complete card verification following the instructions provided on PIXTUB's website.

2. Specific EDD Measures
PIXTUB must apply Enhanced Due Diligence (EDD) measures on a risk-sensitive basis in any situation that by its nature can present a higher risk of Money Laundering and/or Terrorist Financing. As part of this, PIXTUB may conclude, under its risk-based approach, that the standard evidence of identity is insufficient in relation to the money laundering or terrorist financing risk, and that it must obtain additional information about a particular client.
For customers identified as high-risk based on PIXTUB’s risk assessment criteria, the following detailed EDD procedures shall be implemented:

1. Enhanced Identification and Verification: PIXTUB will collect additional information beyond standard identity verification, such as source of funds and business activities.
2. Enhanced Monitoring: Continuous monitoring of high-risk customers' transactions and activities to detect suspicious patterns promptly.
3. Periodic Reviews: More frequent reviews of high-risk customers, including re-assessment of risk profiles and updating of customer due diligence information.
4. Senior Management Approval: Any high-risk customer relationship or transaction must be approved by senior management after thorough review and assessment.

1. Initial screening during account opening or onboarding of new users.
2. Periodic re-screening of existing users in line with regulatory requirements and internal policies.
3. Utilizing a reliable and up-to-date screening database or service provider.

1. Training Programs: We regularly conduct sessions to educate employees on AML and KYC regulations, policies, and procedures.
2. Training Content: Our training includes modules on identifying suspicious activities, proper user verification processes, and reporting protocols.
3. Continuous Education: We ensure ongoing education and updates for employees to keep up with changes in laws and industry practices.
4. Record of Training: We maintain records of all training sessions conducted, including attendance and training materials used.

1. Collecting user’s identification information
2. Developing and revising internal policies and procedures to ensure the comprehensive preparation, review, submission, and retention of all necessary reports and records, in compliance with relevant laws and regulations.
3. Monitoring transactions and investigating any notable deviations from standard activity.
4. Establishing a structured records management system for the efficient storage and retrieval of documents, files, forms, and logs.
5. Periodically updating risk assessments.
6. Providing law enforcement with pertinent information as required by applicable laws and regulations.

1. Daily screening of users against recognized "blacklists" like OFAC, which includes aggregating transfers based on various data points, placing users on watchlists or denial lists, initiating necessary investigations, sending internal communications, and completing statutory reports when needed.
2. Efficient management of cases and documents.

1. Report suspicious transactions to law enforcement via the Compliance Officer.
2. Request additional documentation and information from users when transactions are suspicious.
3. Suspend or terminate a user's account if there is reasonable suspicion of illegal activity.

1. Policy Review: We conduct a comprehensive review of AML and KYC policies at least once a year.
2. Regulatory Changes: Policies are promptly updated to reflect any changes in relevant laws and regulations.
3. Internal Audit: Regular internal audits are performed to ensure compliance with AML and KYC policies.
4. Feedback Mechanism: We have a system in place to receive and incorporate feedback from employees and stakeholders on the effectiveness of our AML and KYC measures.

1. Document Copies: We retain copies of documents and information obtained through Customer Due Diligence (CDD) measures, including electronic identification data.
2. Transaction Evidence: We preserve evidence confirming conducted transactions and records of these transactions, whether original documents or copies, required for identification purposes.
3. Analysis Results: We keep records of ongoing analyses of executed transactions.

The retention period may be extended by up to five additional years if required by law. The primary purpose of record keeping is to provide a comprehensive trail of evidence to assist the Compliance Officer and authorities in investigating money laundering allegations. This practice is vital for supporting financial investigations and preventing illicit funds from entering the financial system. If such funds do enter, proper record keeping aids in their identification and seizure by authorities. Records must be securely stored and easily retrievable within 24 hours when necessary, regardless of whether they are in paper or electronic format.