This Anti-Money Laundering Policy ("AML Policy") of the Atlantis Exchange is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. 

This AML Policy sets out the minimum standards which must be complied with and includes:

    1. The appointment of a Money Laundering Reporting Officer ("MLRO") who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;

    2. Establishing and maintaining a risk-based approach ("RBA") towards assessing and managing the money laundering and terrorist financing risks to the Atlantis Exchange;

    3. Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons ("PEP");

    4. Establishing and maintaining risk-based systems and procedures to monitor on-going customer activity;

    5. Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

    6. The maintenance of appropriate records for the minimum prescribed periods; and

    7. Training and awareness for all relevant employees.

In addition:

    8. Atlantis Exchange takes a risk-based approach when adopting and implementing counter financing of terrorism ("CFT") measures and in conducting AML risk assessments. Atlantis Exchange adopts internal CFT controls and makes undefended decisions regarding CFT matters supersedes any business, strategic or other operating task.

    9. Atlantis Exchange will not make transacting with individuals, companies and countries that are on prescribed international sanctions lists.

    10. Atlantis Exchange identifies each registered individuals by obtaining his/her passport, ID, or other identification document and utility bills stating their current postal address. Companies have to be identified by extracts from the Chamber of Commerce or by notary deed or by government issued license. Copies have to be made and archived in files securely.