AML/KYC

Greetings!

Clakson OÜ, our subsidiaries, agents, partners, and affiliates are collectively referred to as “Clakson”, “we”, “us”, and “our”. Clakson owns, operates, and provides a Website https://clakson.net/.

This AML/KYC Policy constitutes an explanation of the Anti-Money Laundering and Know Your Customer approaches in Clakson according to our Services.

Supplemental terms and conditions or documents that may be posted on the Website are hereby expressly incorporated herein by reference. We reserve the right to change this AML/KYC Policy occasionally, without prior notice and your consent.

Other terms used in this AML/KYC Policy, but not defined, have similar meanings to those in the Terms of Use.

Anti-Money Laundering (AML)

We are committed to complying with various regulatory requirements related to anti-money laundering rules imposed by applicable laws and regulations. This policy is based on managing compliance risks arising from our customers, and we oversee the following:

• Ongoing compliance with the requirements introduced by national and international laws, regulations, and sanctions;
• Implementation of the risk-based "Know Your Customer" and "Customer Activity Monitoring" principles;
• Determination and reporting of suspicious transactions.

For this purpose, we are required, among other things, to fulfill the following requirements:

• Understand and interpret the legal and regulatory framework for AML/CTF requirements and systems;
• Understand standard industry best practices in AML/CTF procedures and use a proportionate risk-based approach;
• Design and implement systems and controls necessary to mitigate the risk of being used in connection with money laundering or financing terrorism.

Know Your Customer (KYC)

KYC is an acronym for "Know Your Customer," a term used for the customer identification process. It involves making reasonable efforts to determine the true identity and beneficial ownership of accounts, the source of funds, the nature of the customer's business, and the reasonableness of operations in the account about the customer's business. The objective of KYC is to prevent payment services from being used, intentionally or unintentionally, by criminal elements for money laundering.

The KYC Policy consists of the following key elements, all of which are governed by our internal policies and operation guidelines:

• A customer acceptance policy: The criteria for determining whether a customer or client can be accepted to open an account – or if the level of risk requires additional due diligence;
• Risk management: The criteria for classifying customers as low, medium, or high risk;
• A Customer Identification Program: Verification of documents to effectively know your customer;
• Ongoing monitoring: Monitoring client or customer accounts for any unusual or unexpected financial transactions that might require reassessing their risk profile.

Risk-Based Approach

The risk-based approach enables the measurement of risks for the potential laundering of proceeds of crime based on the field of activity, identification of the criteria, and activation of appropriate means and methods for mitigating and controlling such risks.

To prevent any transactions concerning the laundering of proceeds of crime and financing of terrorism, we arrange and organize the works required for the implementation of adequate procedures for monitoring the customers' transactions, related reporting, retention of records, organization of training activities, and performance of internal auditing activities, with a risk-based approach; and ensure that any risks falling under such scope are controlled.

We duly assess current country risks and other risks under our internal policies, which are based on applicable regulations.

Stages of KYC Procedure

KYC procedures have approximately the following stages:

• Obtaining information from the customer according to the relevant questionnaire for individuals or legal entities;
• Obtaining documents and other evidence from the customer that prove the information provided in the relevant questionnaire;
• Validating the provided information and proofs through screening the customer in public registers;
• Filing the information to proceed with compliance and AML risk evaluation according to our internal policies;
• Continuously checking the client's identification data during the term of the contractual relationship.

All data obtained during KYC is kept for ten years.

Duty to Identify Customers

Under applicable AML/KYC regulations, we must identify prospective customers' identities. The procedure is obligatory in the following cases:

• Before establishing a business relationship with customers,
• When the transaction is more than EUR 700,
• When the transaction of the identified customer exceeds EUR 10,000,
• When a politically exposed person is involved,
• Whenever a transaction relates to the objects of cultural value,
• Whenever a transaction relates to the objects of cultural value, second-hand goods, or goods without proof of their acquisition to mediate their sale or acceptance of a pledge;
• Whenever a transaction relates to the life assurance premium;
• If the exact amount of the transaction is not known;
• In case of signs of a suspicious transaction;
• In other cases where it is necessary to identify.

Identification of Customers

Prospective customers or their representatives based on a power of attorney during the KYC process before the establishment of business relationships should fill out the respective questionnaire provided by us and submit duly prepared copies of documents that evidence the submitted information. The information we will require during the KYC process includes, among others, the following:

• Personal identification information (name, surname; passport data, tax ID, DOB, date and place of birth, permanent residency address, citizenship, etc.);
• Company details, beneficial owners, information on the company’s management, etc.;
• Whether the client or related persons are politically exposed persons;
• Whether the client or related persons are sanctioned persons;
• Other information as per the relevant questionnaire.

We have the right to ask to provide other information not specified here for KYC purposes. For registration to the system via the website, the client is obliged to:

• Upload on the website the required copies of documents and other supporting documents to verify all the submitted information;
• Upload on the website a document confirming the existence of an account held in the name of the client with a credit institution;
• Send the first payment from a bank account that the client has documented.

When the documents are presented online in electronic form, they shall be uploaded to the customer’s profile webpage as high-resolution color photos with evidence that these documents were submitted by the customer personally and are up to date.

Outsourcing of Identification Duty

We may use the services and tools of another authorized institution that complies with the applicable requirements to perform customer identification and verification.

Our Statement Regarding Country Restrictions

At our company, we take our legal and ethical responsibilities seriously. We are committed to complying with all applicable rules and regulations governing our operations. Therefore, we do not cooperate with companies or individuals from sanctioned countries or provide our services in those countries. As a result, our services are not available in or for the following countries or territories:

• russia;
• belarus;
• Crimea and Sevastopol city;
• so-called Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR);
• temporarily occupied territories of Ukraine;
• Iran;
• North Korea;
• Syria;
• Cuba.

In addition, we do not cooperate, and our services are not available to entities or individuals owned or controlled by or acting for or on behalf of residents of such countries. We have implemented strict policies and procedures to ensure that our business activities are always conducted within the law. We believe that our commitment to compliance and ethical conduct is not only a legal obligation but also a moral imperative.

Miscellaneous

Effective date. This version of the AML/KYC is valid from the Effective date.

Governing Law. This AML/KYC Policy shall be governed by and construed under the laws of Estonia, without giving effect to any principles of conflict of laws.

Disputes. All disputes or claims about this AML/KYC Policy are resolved within 30 business days of negotiation, if negotiation doesn’t work the court of Estonia under Estonia law must resolve it. The defeated party should pay all reasonable court and attorneys’ fees and costs.

Changes. We may make changes from time to time without your consent. The new version will be valid from the time of the changes noted at the beginning of this AML/KYC Policy.

Languages. This AML/KYC Policy is available in English. If there are any differences between the English and any other translated versions, the English version shall prevail.

Contact Information

Direct Contact. You can contact us electronically via email at [email protected].

Contact Person. You can send to us a paper letter on Harju maakond, Tallinn, Lasnamäe linnaosa, Väike-Paala tn 2, 11415. Contact person is Eesti Firma OÜ.

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