Last revised Nov. 2025
1.1. This AML/KYCPolicy (hereinafter referred to as the “Policy”) sets forth therules, principles and procedures that the Fortecrypt Alliance s.r.o., itssubsidiaries and affiliated parties (hereinafter referred to as the “Company”)follows for detecting and preventing any financial crime, including moneylaundering and the funding of terrorism, in accordance with all relevant andmandatory applicable laws.
1.2. This Policyis an integral part of the Company’s Terms of Services – i.e. the terms andconditions, which are at all times available on the Company’s Website. ThePolicy specifies the main and general principles and rules, applicable for thepurposes of detecting and preventing any financial crime, including moneylaundering and the funding of terrorism, in accordance with all relevant andmandatory applicable laws.
1.3. The Company is strongly committed to preventing theuse of its Services for money laundering or any other activity whichfacilitates money laundering, the funding of terrorist and/or any othercriminal activities, or any other illicit purposes.
1.4. The Company has its own implemented internalprocedures (hereinafter referred to as the “Procedures”),developed and implemented in accordance with the Act No. 297/2008 Coll. onprotection against money laundering and terrorist financing and on theamendment to certain acts, as well as other by-laws adopted on the basis ofthis Act and other applicable, relevant and mandatory legal requirements(hereinafter altogether referred to as the “AML/CFT Laws”). TheProcedures are administered by the Company’s Director, the AML Officer (MLRO),and his team, together referred to as the Compliance Department in strictaccordance with the AML/CFT Laws.
1.5. The Company’s Compliance Department is tasked withmonitoring compliance with the relevant AML/KYC regulations and administratingthe Procedures within the Company in strict accordance with applicable laws.
2.1. The Companyprovides licensed virtual asset services, permitted in accordance with theAML/CFT Laws, as well as specified in the Terms of Services.
2.2. The Companyadministers and applies its AML/KYC principles, rules, measures and proceduresin strict accordance with the AML/CFT Laws for the purposes of detecting andpreventing any financial crime, including money laundering and the funding ofterrorism and any other illegal activity.
3.1. The Company has its own developed and implementedprotection measures, which protect the Company from being involved and theCompany’s Users from carrying out any suspicious financial activity, businessand transaction(s). For these purposes, the Company:
4.1. As part of the User’s Due Diligence, the Company’sCompliance Department:
4.2. The Company has the right to request additional, newand/or updated data, documents and/or information from any User at any time,even if such User has been identified before in accordance with applicablelaws.
4.3. The Company may stop and refuse providing Servicesto Users and/or report such Users to the authorized government bodies, if theydo not provide the Company with requested data, documents and/or information inaccordance with applicable laws.
5.1. The Company implements and applies different AML/KYCVerification Levels to detect and prevent any financial crime, including moneylaundering and the funding of terrorism, in accordance with AML/CFT Laws.
5.2. The Company’s Verification Level, conducted on eachUser, shall directly influence the amount of activities the User can perform onthe Company’s website. For the purposes of the Company’s Verification Levels,the following terms shall have the following meaning:
The Valid ID shall mean document, which contains thefollowing:
● Names and surname;
● Date of birth;
● Place of birth;
● Gender;
● The number of the identity document;
● The date and place of issue;
● The name of the authority which issued it;
● Period of validity;
● Photo.
As Valid ID we accept such documents as national identitycard, passport, driving license аnd/or residence permit
The Proof of Residence shall mean a recent (up to 6months) utility bill (e.g. electricity, water, cable TV, internet line,telephone landline), bank statements, and/or and/or municipal taxes and/or taxinvoices.
5.3. In accordance with the applicable AML/CFT Laws, aswell as the Company’s internal compliance procedure rules, when making atransaction or a series of linked transactions and/or at any time requested bythe Company, a User shall provide a Proof of Funds, which shall mean anydocument that verified the lawful source of User’s funds, such as copies ofaccounting documents, tax statements, bank statements and so on.
5.4. For the purposes of the Company’s VerificationLevels and/or at any time the Company may also send a User an AML/KYCQuestionnaire, which shall mean a series of questions and/or a video-call withthe Company’s Compliance Department in order to detect and identify the intentand the source of funds, that are subject to User’s business, transactions andactivities, as well as to rule out any illicit purpose.
6.1. When carrying out risk assessment, as well asinitial and/or ongoing Procedures, the Company takes into account the riskfactors, including the User’s and the geographical risk characteristics.
6.2. When carrying out risk assessment, the Company takesinto account the untruthful, false and/or incomplete data, information,documents and facts, including but not limited to discrepancies in ID documentsprovided, fictitious person, stolen identity, previous financial crime record,terrorist record, wanted person and so on.
6.3. When carrying out risk assessment, the Company alsopays attention to the performance of suspicious, high-volume and unusualtransactions and/or series of linked transactions by its User(s).
6.4. When carrying out risk assessment, the Company, inaccordance with its internal procedure rules, may apply simplified or enhancedAML/KYC measures in accordance with the AML/CFT Laws and based on the results(outcomes) of the risk assessment.
6.5. The Company has its own developed and implementedlist of countries, with whom it does not work with. The list of countries isbased on the list of countries identified by the EU as high risk, as well asthe list of countries identified as being at risk by the Financial Action TaskForce (FATF). The lists created by EU and FATF are essential for assessing therisk of Users, transactions and/or business relationships.
7.1. The Company carries out ongoing monitoring ofactivities to prevent money laundering, terrorism financing, and other illegalactivities. As part of the monitoring activities, the Company:
8.1. In an event that the Company reasonably suspectssuspicious transaction(s), it shall conduct additional questioning regardingthe User’s activity by the means of the AML/KYC Questionnaire, and request anyadditional data, documents and/or information, that may be required for thesepurposes and in accordance with applicable AML/CFT Laws, as well as regulatoryrequirements and guidelines.
8.2. In case the User has not provided any data,document, information and explanation about the suspicious transaction(s), acomplete set of requested documents, and/or has presented suspicious or unusualdata, documents and other information that the Company cannot verify, theCompany will reasonably suspect that the User’s business, activities andtransaction(s) may be connected to money laundering, terrorism financing orother illegal activity, business and transaction(s). In such cases the Company filesa report on the website of authorized government body, reporting the suspiciousactivity, business and transaction(s) and reserves the right to suspend theUser’s account, suspected of such activities, business and transaction(s) atits sole discretion.
9.1. If you have any questions about this AML/KYC Policy,procedures and/or any other AML/KYC-related matters or any complaints aboutCompany’s Services, you may contact us at compliance@valeto.co
