Internal Program to Prevent Money Laundering and Terrorist Financing

1. Introduction
This document outlines the internal policies and procedures of our company to prevent money laundering and terrorist financing in the context of trading virtual currencies.

2. Legal Framework
Our company commits to adhering to all applicable laws and regulations of the Slovak Republic and the European Union regarding the prevention of money laundering and terrorist financing.

3. Definitions
Virtual Currency: A digital representation of value that can be electronically transferred, stored, or traded.
Money Laundering: The process of concealing the true origin of funds obtained from criminal activities.
Terrorist Financing: Providing financial resources with the intent to support terrorist activities.

4. Risk-Based Approach
Our company applies a risk-based approach in identifying and assessing risks associated with trading virtual currencies to ensure effective prevention and detection of potential money laundering and terrorist financing cases.

5. Client Identification and Verification
Before establishing a business relationship, it is necessary to:

Obtain and verify the client's identification data.
Verify the client's identity through independent and reliable sources.
Identify the purpose and intended nature of the business relationship.

6. Transaction Monitoring
The company will continuously monitor all transactions to identify and report unusual and suspicious activities, including:

Analyzing transaction patterns and client behavior.
Identifying unusual or suspicious transactions that may indicate money laundering or terrorist financing.

7. Employee Training and Education
The company will ensure regular training and education of all employees on current regulations and procedures in the field of preventing money laundering and terrorist financing.

8. Reporting Suspicious Activities
In case of detecting suspicious activities, the company is obligated to report these facts immediately to the relevant authorities according to applicable legal regulations.

9. Data Storage and Protection
The company will ensure the secure storage of all obtained data and information in compliance with applicable data protection laws, and such data will be retained for the period required by law.

10. Regular Review and Update of the Program
This program will be regularly reviewed and updated to reflect current risks and legislative changes in the area of preventing money laundering and terrorist financing.

11. Politically Exposed Persons (PEP)
Politically exposed persons are individuals in prominent public positions. The company will apply enhanced due diligence and transaction monitoring when dealing with these individuals.

12. Unusual Business Operations
An unusual business operation is any legal or other act that may indicate money laundering or terrorist financing, such as:

Transactions with unusually high amounts of financial resources.
Transactions without an apparent economic or legal purpose.
Clients refusing identification or providing incomplete information.

13. Responsibility and Internal Control
Every employee is responsible for complying with this program and must report any suspicious activities. The company implements internal control mechanisms to ensure the effective implementation of this program.

This program aims to ensure a high level of protection against money laundering and terrorist financing, considering the specifics of trading virtual currencies.