Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

28 Apex OOD ("GO28") is firmly committed to participating in international efforts to combat money laundering, the financing of terrorism, and other illicit financial activities. To comply with the Bulgarian Law on Measures Against Money Laundering, the EU's 5th and 6th Anti-Money Laundering Directives (AMLD5/AMLD6), and other relevant regulations, we have implemented a comprehensive and risk-based Anti-Money Laundering (AML) and "Know Your Customer" (KYC) Policy.

This policy is integral to our business operations and applies to all clients. Failure to comply with these procedures will result in the immediate refusal to open an account or the termination of an existing business relationship.

We implement a robust, multi-layered Customer Identification Program to establish and verify the identity of all our users before they can conduct financial transactions. This is a crucial prerequisite for using our services, particularly those involving fiat currency.

2.1. Customer Due Diligence (CDD) - Verification Levels

We employ a tiered approach to verification:

• Level 1 (Basic Information): Upon registration, all users must provide their full legal name, residential address, and date of birth. This allows for basic account setup but with limited functionality.
• Level 2 (Full Verification): To access fiat currency deposit/withdrawal services and higher transaction limits, users must complete our full verification process. This includes submitting a valid, unexpired government-issued identification document (e.g., Passport, National ID card) and a real-time biometric "liveness check" to confirm the document belongs to the user.

2.2. Enhanced Due Diligence (EDD)

For users or transactions identified as potentially high-risk, we conduct Enhanced Due Diligence. Triggers for EDD include, but are not limited to, a user's status as a Politically Exposed Person (PEP), transactions originating from high-risk jurisdictions, or transaction patterns that are unusually large or inconsistent with the user's known profile. EDD may require obtaining additional information, such as the user's source of funds or source of wealth.

3.1. Ongoing Monitoring

We utilize sophisticated automated systems and manual oversight to conduct ongoing monitoring of user transactions in real-time. This system is designed to detect and flag activity that is unusual or suspicious. Red flags include, but are not limited to, rapid deposits and withdrawals, transactions structured to fall just below reporting thresholds, or transactions with wallets known to be associated with illicit activity.

3.2. Suspicious Activity Reporting (SAR)

When our team identifies an activity that we suspect may be related to money laundering or terrorist financing, we are legally obligated to file a Suspicious Activity Report with Bulgaria's Financial Intelligence Directorate of the State Agency for National Security (SANS-FID). These reports are filed confidentially and without notifying the customer involved, as required by anti-tipping-off laws.