AML:CTF and KYC Policy

Anti-Money Laundering, Counter-Terrorist Financing and Know Your Client Policy

Last updated: 10/03/25

1. Introduction

This Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) Policy establishes the framework for preventing the misuse of Geritdan for illicit activities. As a cryptocurrency platform, we recognize the heightened risks associated with digital assets, including anonymity, cross-border transactions, and rapid value fluctuations. 

Anti-money laundering (AML) refers to the laws, regulations and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

This policy complies with the Polish AML Act, EU AML Directives, and Financial Action Task Force (FATF) standards.

 

2. Objectives

• To prevent, detect, and report suspicious activities related to money laundering and terrorist financing.
• To ensure compliance with Polish and international AML/CTF regulations.
• To protect the platform, its users, and stakeholders from exposure to financial crime.
• To maintain a robust system for verifying the identity of customers (KYC) and monitoring transactions.

 

3. Legal and Regulatory Framework

This policy aligns with:

• Polish AML Act (Ustawa AML) – Act of March 1, 2018 (as amended),
• EU Directives on AML and CTF, including the 5th and 6th AML Directives,
• FATF (Financial Action Task Force) Recommendations,
• General Data Protection Regulation (GDPR) for data protection and privacy.

 

4. Scope

This policy applies to:

• All users of the platform (retail and institutional),
• All employees, contractors, and agents of Geritdan,
• All services, including cryptocurrency trading, exchange, wallet services, and token offerings (if applicable).

The policy addresses the risks associated with:

• Cryptocurrency-to-cryptocurrency (crypto-to-crypto) transactions,
• Cryptocurrency-to-fiat and fiat-to-cryptocurrency conversions,
• Custodial and non-custodial wallet services,
• Use of privacy-focused cryptocurrencies or mixers.

 

5. Risk Assesment

The European Union has implemented comprehensive legislation to combat money laundering and terrorist financing, aligning with global efforts to address these issues. The European Commission ensures the effective enforcement of these laws by overseeing their integration into national frameworks and collaborating with networks of relevant authorities.

The Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) evaluates compliance with key international standards for combating money laundering and terrorism financing. It also assesses the effectiveness of their implementation and provides recommendations to national authorities for necessary system improvements. Additionally, MONEYVAL conducts specialized research to analyze trends and patterns in money laundering and terrorism financing.

The Financial Action Task Force (FATF) monitors emerging or evolving techniques used by criminals to launder illicit gains and by terrorists to fund their activities. FATF publishes typology reports to increase awareness among authorities and the private sector about the risks associated with specific sectors or products, helping stakeholders take proactive steps to mitigate these risks.

To fulfill its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations, Geritdan conducts an annual AML Risk Assessment. This assessment aims to prevent misuse of Geritdan for money laundering by identifying potential risks and evaluating the effectiveness of controls in place. Geritdan adopts a risk-based approach to verify users and monitor their interactions with its services.

The Compliance Officer oversees the management of financial crime risks and continuously works to enhance the organization's financial crime risk management framework. This involves identifying general and specific money laundering risks faced by Geritdan, evaluating how these risks are mitigated through the company's AML controls, and determining the residual risk that remains.

We classify users, transactions, and activities into risk levels:

• Low-Risk Users: Verified users with standard transaction patterns.
• High-Risk Users: Politically exposed persons (PEPs), users from high-risk jurisdictions, or users transacting in privacy coins.
• High-Risk Transactions: Transactions exceeding predefined thresholds, those involving mixers, or transfers to/from unregulated platforms.

 

6. Know Your Customer (KYC) Application

The Company seeks to reduce the risks related to money laundering, terrorist financing, and other unlawful activities by adhering to the following principles.

Identity Verification

All users are required to complete KYC before accessing the platform’s full functionality. This involves:

For Individual Users:

1. Full name, nationality, date of birth,
2. Residence or domicile,
3. Nationality,
4. Citizenship,
5. Photo ID (passport, national ID),
6. Selfie with the ID document to confirm identity,
7. Proof of address (e.g., utility bill or bank statement, issued within the last three months),
8. Other documents at the discretion of our Compliance Team.

For Corporate Users:

1. Email address
2. Mobile phone number
3. Legal name
4. Registration code
5. Registered address
6. Business address
7. Incorporation details
8. Information on the legal form and legal capacity of the authorized person
9. The data on the members of the management board and nature of their representative right to represent the legal entity
10. The data on the representatives
11. The data on the actual beneficial owners
12. Other information at the discretion of our Compliance Team
13. Proof of legal existence, good standing of the legal entity, and other legal documents (e.g., business registry extract, certificates, articles of association)
14. Identification documents of beneficial owners (UBO) and directors
15. Proof of address
16. Other documents at the discretion of our Compliance Team.

Enhanced Due Diligence (EDD)

EDD is required for:

• High-risk users, including PEPs and customers from high-risk jurisdictions,
• Transactions exceeding €15,000 (or equivalent in cryptocurrency),
• Customers dealing in privacy-focused cryptocurrencies,
• Unusual or complex transaction structures.

EDD measures include:

• Verifying the source of funds/wealth,
• Additional identity verification steps,
• Ongoing transaction monitoring.

Continuous Monitoring

We utilize automated tools to monitor transactions for:

• Anomalies in transaction patterns,
• Links to high-risk wallets (e.g., blacklisted addresses),
• Transfers involving mixers or tumblers.

 

7. Transaction Monitoring

To trade on Geritdan, all users are required to complete the identity verification process to confirm their identity ("who you are"). Once verified, users consent to transaction monitoring, where Geritdan reviews and analyzes their transactional activity ("what they do").

Geritdan utilizes advanced data analysis tools to assess risks and detect suspicious activities. These tools facilitate various compliance functions, including data collection, filtering, record-keeping, investigation management, and reporting.

As part of its AML/CFT and KYC Policy, Geritdan will:

• Monitor all transactions and reserves the right to report any transactions of a suspicious nature to the appropriate authorities.
• Request additional information or documentation from users if a transaction appears suspicious.
• Suspend or terminate services to a client if there is reasonable suspicion that the client is involved in illegal activities.

This list is not exhaustive. The Compliance Officer will regularly review and assess user transactions to determine whether they should be flagged or reported as suspicious.

 

8. Suspicious Activity Reporting (SAR)

Suspicious transactions are reported to the General Inspector of Financial Information (GIIF). 

Examples include:

• Transactions structured to avoid thresholds,
• Large volumes of small transactions (smurfing),
• Use of cryptocurrencies in jurisdictions with weak AML/CTF enforcement.

 Sanctions Screening

The platform screens users and wallet addresses against:

• International sanctions lists,
• Watchlists maintained by the Polish Financial Supervision Authority (KNF) and FATF,
• OFAC (Office of Foreign Assets Control) sanctions lists.

 

9. Prohibited Activities

The following activities are strictly prohibited:

• Use of the platform for money laundering, terrorism financing, fraud, or tax evasion,
• Transactions with blacklisted wallet addresses or entities,
• Use of mixers, tumblers, or other anonymization services,
• Dealing with privacy coins (if restricted by platform policy).

 

10. Training and Awareness

All employees and agents of Geritdan are required to undergo training on:

• Identifying and reporting suspicious activities,
• Cryptocurrency-specific AML/CTF risks,
• Updates to Polish and EU AML laws.

 

11. Record Keeping

The platform retains all KYC and transaction records for at least five years, as required by Polish AML legislation. This includes:

• User identification documents,
• Transaction logs (including wallet addresses and transaction hashes),
• SAR and CTR filings.
• Records are stored securely and accessible only to authorized personnel.

 

12. Data Privacy

User data is handled in compliance with GDPR. All personal data collected for KYC purposes is:

• Used solely for AML/CTF compliance,
• Stored securely with encryption,
• Not shared with third parties except as required by law.

 

13. Cooperation with Authorities

Geritdan cooperates fully with Polish authorities, including the GIIF, KNF, and law enforcement agencies. This includes:

• Responding to information requests,
• Assisting in investigations of financial crimes.

 

14. Policy Review and Updates

This policy is reviewed annually or when there are significant changes in the regulatory or operational environment. Users will be notified of any material changes.

 

15. Contact Information

For questions or concerns related to AML/CTF and KYC procedures, please contact:

Geritdan Sp. z o.o.

Hoza street 86/210, Warsaw, 00-682, Poland

Email: [email protected]