KYC Policy & AML Program

KYC POLICY & ANTI-MONEY LAUNDERING PROGRAM

XVA Blockchain GmbH policies are committed to combating money laundering, terrorist financing, securities fraud and other financial crimes (collectively “money laundering”) and complying fully with all applicable laws and regulations relating to combating money laundering.
Advanced Blockchain Solutions is also committed to complying with economic and trade sanctions administered and enforced by governments and supranational bodies, including, among others, BaFin in Germany and therefore the European Union.
Any individual who engages in money laundering, or who fails to comply with all applicable KYC & AML laws, regulations, and KYC & AML policies of Advanced Blockchain Solutions GmbH, will be subject to disciplinary action. With respect to our clients or counterparties, the firm reserves the right to terminate immediately any business relationship that violates or presents the risk of violating such laws, regulations or policies of the firm.

Advanced Blockchain Solutions GmbH AML compliance program contains the following components:

1. Designation of a Global AML Compliance Officer
2. Risk Assessment
3. Training
4. Independent Testing
5. Automated STP (Straight Trough processing) for KYC & Internal Policies and Procedures, including the following:
   • Customer identification and customer due diligence programs and enhanced due diligence of customers presenting higher risk
   • Government sanctions – e.g. BaFin
   • Suspicious activity monitoring and reporting
   • Reporting and recordkeeping requirements
   • Receipt and response to information requests Training

June 13th, 2018

Alexander J. Boos (CCO & Global AML Compliance Officer)

Thomas A. Schwiertz (CEO & CRO)

Directors of Advanced Blockchain Solutions GmbH