AML & KYC POLICY

Last updated: 20 February 2025

Vysoty, LLC (“Vysoty,” “Company”) is dedicated to maintaining the highest standards of integrity, transparency, and compliance with applicable laws and regulations worldwide, including those of the Kyrgyz Republic. We have zero tolerance for money laundering, the financing of terrorism, or any other form of unlawful activity. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines our commitment to preventing and detecting financial crime and ensuring that all transactions conducted via our platform are legitimate.

These rules apply to all individuals and entities associated with the Company, including employees, board members, partners, clients, and contractors.

1. PURPOSE OF THIS DOCUMENT

This document offers a concise overview of the components and procedures within Vysoty’s Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) compliance regime. It is intended to inform our partners, clients, vendors, contractors, employees, regulators, law enforcement, and other stakeholders interested in our AML/CTF measures.

Please note that this document does not represent an exhaustive account of all policies, procedures, and controls that Vysoty has in place to prevent money laundering, terrorist financing, and other illegal activities.

2. THE COMPANY DEFINES MONEY LAUNDERING AS FOLLOWS:

1. Converting or Transferring Property

Any act of converting or transferring property, with the knowledge that such property originates from criminal activity (or one’s involvement in criminal activity), for the purpose of concealing or disguising its illicit origin. This may also include assisting anyone engaged in such activities to evade legal consequences.

2. Concealing or Disguising Property

Any act of concealing or disguising the true nature, source, location, disposition, movement, or ownership of property, with the knowledge that this property is derived from criminal activity.

3. Acquiring, Possessing, or Using Criminally Derived Property

Acquiring, possessing, or using property while knowing, at the time of receipt, that it was obtained through criminal activity or one’s involvement in such activity.

4. Participation or Facilitation

Engaging in, conspiring to commit, attempting, aiding, abetting, facilitating, or counseling any of the actions outlined in points 1, 2, and 3.

Terrorist financing entails the provision of funds for terrorist activities. Legally, it encompasses acquiring or collecting funds—either directly or indirectly, and by any means—with the intention or knowledge that the funds will be used, in whole or in part, to enable any form of terrorism.

Such terrorist activities aim primarily to intimidate a population or pressure a government into specific actions. They are carried out through deliberate acts of violence or threats, such as intentional killing, causing serious harm or endangerment to individuals, significant property damage with high potential for harm, or severe disruption of essential services, facilities, or systems.

LEGAL FRAMEWORK

As a regulated business, Vysoty, LLC is required to comply with relevant anti-money laundering and terrorist financing legislation. In accordance with international standards, including the Financial Action Task Force (FATF) Recommendations, we:

• Verify our clients’ identities and conduct ongoing monitoring of transactions,
• Maintain records of client activity and related documents for at least five (5) years, and
• Report certain transactions or activities to the appropriate authorities as mandated by law.

Our compliance with these obligations is strictly non-negotiable.

3. RISK-BASED APPROACH AND RISK ASSESSMENT

5.1. This Offer is effective from the date of its publication on the website (www.vysoty.io) and remains in effect until revoked by the Company.

Vysoty employs a risk-based approach in its due diligence practices, gathering information and documentation to assess each prospective client’s risk profile. Our dedicated team exercises diligence, sound judgment, and great care in comprehensively evaluating every client’s character and activities. We are unwavering in our commitment to ethical business practices and will not partner with individuals or entities who could compromise our reputation or the integrity of the broader industry in which we operate.

In evaluating money laundering and terrorist financing risks, Vysoty prepares a thorough risk assessment considering:

• Customer risk
• Geographical risk
• Product risk
• Delivery channel risk

Based on the degree of risk assigned to a customer, the assessment may be periodically revised as we gain further knowledge of the customer’s profile and ongoing activities.

COMPLIANCE OFFICER

The Company’s management board designates a Compliance Officer who:

• Oversees the Company’s AML/CTF obligations,
• Serves as a primary point of contact for the Financial Intelligence Unit (FIU),
• Has the requisite expertise, impeccable reputation, and direct access to information across the Company’s divisions, and
• Reports directly to the management board.

The Compliance Officer’s duties include, but are not limited to:

• Organizing the collection and analysis of information related to unusual or suspicious transactions,
• Reporting to the FIU if there is suspicion of money laundering or terrorist financing,
• Submitting regular written statements on compliance to the management board,
• Fulfilling other tasks necessary for adherence to the law.

4. AML COMPLIANCE PROGRAM

4.1. Due Diligence

Vysoty employs the following due diligence measures:

1. Customer Identification and Verification

   Confirming customer identity with reliable, independent sources (including electronic methods).

2. Beneficial Ownership Identification

   Understanding the ownership and control structure of corporate clients and taking steps to confirm actual beneficial owners.

3. Business Relationship Understanding

   Determining the intended nature of the business relationship and collecting relevant information.

4. PEP Screening

   Checking whether the customer is a politically exposed person (PEP), a family member of a PEP, or a known close associate.

5. Sanctions Screening

   Reviewing customers against applicable sanctions lists.

6. Ongoing Monitoring

   Monitoring business relationships and transactions to detect any anomalies or suspicious activities.

4.2. Transaction Monitoring

We use advanced transaction monitoring tools to identify suspicious or unusual activities:

• All transactions are continuously assessed against the customer’s typical profile.
• If a transaction appears suspicious, Vysoty reserves the right to seek additional documentation or explanation from the customer.
• The Compliance Officer compiles and submits Suspicious Transaction Reports (STRs) to relevant authorities as needed.

4.3. AML Training

Vysoty ensures all personnel and relevant stakeholders receive regular AML training to stay informed of the latest regulations and best practices. The scope and frequency of training depend on changes in legislation, employee roles, and shifts in our business model. This program aims to keep our team updated on emerging patterns and methods of money laundering and terrorist financing.

4.4. Record Keeping

Vysoty maintains detailed records of customer data, transactions, and AML-related documents for at least five (5) years after the termination of a business relationship. Personal data gathered for AML/CTF purposes is processed only for preventing money laundering and terrorist financing and will not be used for other unrelated purposes (e.g., marketing).

5. REPORTING AND COMPLIANCE

5.1. Reporting Suspicious Activities

If Vysoty detects any activity or scenario suggesting the use of criminal proceeds, terrorist financing, or other illegal conduct—or if circumstances lead us to suspect money laundering or terrorist financing—our Compliance Officer will promptly report the incident to the relevant Financial Intelligence Unit (FIU) or authority.

5.2. Compliance Reviews

We conduct routine internal AML compliance reviews to gauge the effectiveness of our program. Any necessary adjustments or improvements are made to ensure Vysoty remains aligned with the latest regulatory developments and best practices.

6. KYC (KNOW YOUR CUSTOMER)

Vysoty prioritizes security and transparency. In order to use our products and services, each user must read and agree to our KYC policy.

KYC stands for “Know Your Customer” (or “Know Your Client”) and involves verifying a user’s identity by requesting personal data. This standardized procedure is key to preventing illegal financial operations—such as money laundering and terrorist financing—and is mandatory for establishing a customer’s identity.

Users who decline to provide requested information should be aware that KYC is a hallmark of a trustworthy platform. Platforms that do not enforce KYC standards disclaim liability for user transactions, which can expose users to increased risks.

Where appropriate, Vysoty may partner with trusted identity verification providers that employ a risk-based approach aligned with FATF recommendations and global/local AML/CFT regulations. These partners leverage industry-leading technology to secure the KYC process.

To complete the KYC process, you may be required to submit:

• A photo or scanned copy of an official ID (e.g., passport).
• A selfie holding the same ID document.

Document verification may take up to two (2) business days from the time of submission, although the actual timeframe can vary.

7. DATA PRIVACY

Vysoty adheres to strict confidentiality and privacy policies. All personal information you provide is kept private and is utilized solely within the scope of our security and compliance obligations.

By agreeing to our KYC policy, you consent to the processing of your personal data and to an identity verification procedure conducted by Vysoty, LLC (or its authorized service providers). This is necessary to safeguard your financial transactions and fulfill legal requirements.

8. CONCLUSION

Vysoty, LLC is firmly dedicated to preventing money laundering and terrorist financing. Our AML and KYC Policies attest to our commitment to maintaining the highest levels of regulatory compliance and operational integrity.

We continuously monitor and modify our AML measures to address new risks and keep pace with evolving regulations, thereby ensuring the safety and security of our platform and user community.

By following these AML and KYC Policies, Vysoty supports a safer, more transparent financial ecosystem while offering reliable, compliant services.

These policies undergo periodic review to guarantee effectiveness and alignment with evolving AML/KYC regulations. Vysoty reserves the right to update or alter these policies as needed, and any material changes will be announced on our official website.

If you have questions or need to report concerns related to AML and KYC compliance, please contact us at:

Email: [email protected]
Address: 46, 76, Skryabin str., Bishkek, Kyrgyz Republic
Vysoty, LLC (Certificate of Registration: 220780-3301-OOO, TIN: 00808202310023)
Website: www.vysoty.io