AML Policy

Dec 21, 2023 
TOP ONLINE SERVICES LIMITED Ltd.

ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY

(March 2023)

1. GENERAL PROVISIONS

1.1. The Anti-Money Laundering and Combating the Financing of Terrorism Policy (hereinafter — the
“Policy”) of TOP ONLINE SERVICES LIMITED Ltd., incorporated and registered under the laws of England, registered at England, Dept 4637 196 High Road, Wood Green, London, England, N22 8HH  (hereinafter — the “Company”), sets out the measures for the prevention of money
laundering and terrorist financing (hereinafter — "ML/CTF”) implemented by the Company in respect of
the platform operated by the Company (the “Platform’”).

The Company follows strict rules to combat money laundering and terrorist financing, as regulated by
local and international laws and provisions, with the aim of preventing any illegal and criminal activities
and any potential involvement of the company in such activities. In this way, TOP ONLINE SERVICES LIMITED Ltd.
applies the current policy in accordance with the Anti-Money Laundering Measures Act (“AMLMA’).

The Policy requires mandatory compliance by the Customer. Customers are required to read, review,
understand, and then agree to the terms below before using or taking advantage of any of the
Company's services.

1.2. All transactions conducted on the Platform, to the best knowledge of the Company, shall be free
from any form of money laundering and terrorist financing activities. In the event any Customer using
the Platform (a “Customer’) fails to comply with the regulations set by the Company in this policy, the
Customer’s account on the Platform will be terminated and/or a report made to the appropriate
authorities in line with this policy. If the Customer is proven to have committed any money laundering,
he is solely responsible for any damage or loss which may occur, and the Company is excluded from
his fraudulent actions. The Company has the right to cancel or deny a transaction on the Platform at
any point if there are suspicions regarding its legality.

1.3. The terms in this Policy should be interpreted as follows:

1.3.1. "Identification document(s)" refer to:

1. National ID cards and passports and any other official identity documents;
2. Documents that identify the registration address of a natural or legal person, such as, but not
limited to, bank statements and utility bills; or
3. Other documents that may be specified and required by the Company.

1.3.2. "A politically exposed person" (PEP) is a natural person who performs or has been entrusted
with the following important public functions in England or a third country:

1. Heads of state, government leaders, ministers and deputy ministers or assistant ministers;
2. Members of parliaments or other legislative bodies;
3. Members of constitutional courts, supreme courts or other high judicial bodies whose decisions
are not subject to subsequent appeal except in exceptional circumstances;
4. Members of audit institutions; members of management bodies of central banks;
5. Ambassadors and heads of diplomatic missions; senior officers of the armed forces;
6. Members of administrative, management or supervisory bodies of state-owned enterprises and
companies with sole proprietorship - the state;
7. Mayors and deputy mayors of municipalities, mayors and deputy mayors of districts and chairs
of municipal councils;
8. Members of management bodies of political parties;
9. Heads and deputy heads of international organizations, members of Management or
supervisory bodies in international organizations or individuals performing equivalent functions
in such organizations.
1.3.3. "Persons associated with a politically exposed person" are individuals who are in the
following relationships with a PEP:
1. Spouses or individuals who live in a factual cohabitation on marital principles;
2. Descendants of the first degree and their spouses or individuals with whom the descendants of
the first degree live in factual cohabitation on marital principles;
3. Ascendants of the first degree and their spouses or individuals with whom the ascendants of
the first degree live in factual cohabitation on marital principles;
4. Relatives by the second degree of consanguinity and their Spouses or individuals with whom
the relatives by the second degree of consanguinity live in factual cohabitation on marital
principles;
5. Any individual who is known to be a joint owner with a PEP of a legal entity or other legal
formation or is involved in other close commercial, professional, or other business relationships
with a PEP;
6. Any individual who is a sole owner or actual owner of a legal entity or other legal formation that
Is known to have been created for the benefit of a PEP.
1.3.3. "Sanctions Lists" are lists of individuals, legal entities and entire countries that are involved or
suspected of involvement in illegal and criminal activities. Such lists are provided by OFAC, the EU, the
UN, etc.
1.3.4. "Beneficial Owner" means:
1. a person who directly or indirectly owns a sufficient percentage of the shares, shares or voting
rights, including by holding bearer shares, according to § 2, para. 1, item 1 of the additional
provisions of the AMLMA;
2. a person exercising contro! within the meaning of § 1c of the additional provisions of the Trade
Act;
3. a person exercising decisive influence in making decisions to determine the composition of the
management and control bodies, transformation, termination of the activity and other matters of
essential importance for the activity, according to § 2, para. 3 of the additional provisions of
AMLMA;
4. aperson who exercises final effective control through the exercise of rights through third parties,
including, but not limited to, granted by virtue of a power of attorney, contract or other type of
transaction, as well as through other legal forms providing the possibility of exercising decisive
influence through third parties, according to § 2, para. 4 of the additional provisions of AMLMA;
5. settlor, trust owner, custodian, beneficiary, or person in whose primary interest the trust is
created or managed, or a person who ultimately exercises control over the trust by direct or
indirect ownership or by other means, or a person holding office, equivalent or similar to the
previously mentioned;
6. a person on whose behalf and/or on whose account a given operation, transaction Or activity is
carried out and who meets at least one of the conditions specified in § 2, para. 1, items 1 — 3 of
the additional provisions of AMLMA;
7. a person acting as a senior executive when no other person can be identified as the beneficial
owner.
1.4. The Company's internal rules set out processes and measures which manage and mitigate the risk
of money laundering and terrorist financing. Those measures include, but are not limited to Customer
due diligence, Ongoing Customer monitoring and screening, collection, preparation, and retention of
documents, data, and information.

2. CUSTOMER IDENTIFICATION AND STANDART DUE DILIGENCE PROCEDURES

2.1. The Company implements its customer identification provisions in the form of verifying the identity
of any individual who wishes to transact with fiat money on the platform the Company operates and the
identity of the beneficial owners of any company/organization that wishes to become a Customer of the
Company as a legal entity. Before establishing a business relationship with a Customer, the Company
identifies and verifies the identification of Customers through the adopted “Know Your Customer”
procedure ("KYC’”).
2.1.1. Identity verification procedure requires the Customer to provide the Company with reliable,
independent-source documents, data and information. The Company reserves the right to collect
Customer's identification information to meet the requirements of the Policy.
2.1.2 The Company will take Steps to confirm the authenticity of documents and information provided
by Customers. All legal methods for double-checking identification information will be used and the
Company reserves the right to investigate certain Customers who match a higher risk profile or appear
SUSPICIOUS.
2.1.3 The Company reserves the right to review Customer's proofs of identity on an on-going basis.
especially where identification information has changed, or activity appears suspicious / unusual for a
particular Customer. The Company can decide which traits / activities are deemed suspicious at its sole
discretion.
2.1.4 The Company reserves the right to request up-to-date documents from the Customers, even if
they have previously passed identity verification.
2.1.5 Customer's identification information will be collected, stored, shared and protected Strictly in
accordance with the Company Privacy Policy.
2.2. Identification of Natural Persons:
2.2.1. Any individual wishing to transact on the platform operated by the Company must be identified
by collecting the following information:
1. full name:
2. date and place of birth:
3. national ID card or international passport:
4. an official personal identification number or another unique item for identification;
5. address of residence;
6. citizenship the person holds;
7. information regarding the professional occupation and activity of the person;
8. source of funds to be used for trading on the platform;
9. expected volume of purchases and sales ona monthly basis.

2.2.2. By means of an automated solution, the following checks are carried out:
1. Identity document verification;
2. Selfies in real time:
3. Match of the person with the image in the identity document;
4. AML screening (international Sanctions lists, IDPs, watch lists and negative media).
2.2.3. For individuals whose trading volume in the last 120 days has exceeded the equivalent of 15,000
euros (29,337.45 BGN), information on the source of funds is also required (completion of a relevant
declaration and provision of an accompanying document that demonstrates the specified origin of
funds).
2.2.4. The procedure for verification of natural persons also applies to managers of legal entities who
wish to use the services provided by the Company through a corporate profile. In this regard, the
manager should create his personal profile on http://;www.bstxchange.com/ and pass the KYC
procedure for individuals.
2.3. Identification of Legal Persons and Other Legal Entities:
2.3.1. For a company or other legal entity to access the Services, it shall provide the following:
1. name and legal form of the entity;
2. country of incorporation;
3. unique identification code;
4. address of the registered office and address of management; a document certifying the address
of the company (statement from a bank account, electricity/water bill or other utility services),
not older than 3 months;
5. e-mail, website, and telephone of the entity;
6. information about the company's activities, licenses, registrations, shares and their trading,
customers, etc..;
/. information regarding the structure of ownership of the entity;
8. last annual financial statement;
9. the expected volume of planned transactions;
10. information regarding the source of funds and the purpose of the business relationship.
2.3.2. The person opening the corporate account is required to provide the information under the point 
2.3.1, as well as documents under point 2.2.1 for each of the ultimate beneficial owners, directors,
managers, and other persons exercising control over the respective legal entity.
2.4. Based on the gathered documents and information, the Company perform a series of manual and
automated checks in order to ensure that the submitted data is complete, true and accurate. The
Company currently uses a verification software solution that allows for additional identity verification
and determines the authenticity and legitimacy of the Customer's documents.
2.5. The Company conducts initial and ongoing Customer screening against international sanction and
watch lists, lists of politically exposed persons, and negative media screening.
2.6. The Company may, at its sole discretion refuse the Opening of or terminate an already exiting
Account of a Customer for which it has been established, or there is a reasonable doubt that any
information about the Customer, obtained in the course of the KYC procedure is incorrect, insufficient,
or in the case where such actions are required in accordance with the applicable legal provisions.
2.7. The Company is prohibited from conducting transactions with individuals, companies and countries
that are on international sanctions lists; therefore, the Company verifies its Customers against the
relevant UN, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) lists, as
well as other sanctions lists.

3. IDENTIFICATION OF POLITICALLY EXPOSED PERSONS, ENHANCED CUSTOMER
DUE DILIGENCE AND ONGOING MONITORING

3.1. The Company has adopted a risk-based approach in its anti-money laundering policy and regards
each Customer verification individually. Based on the information gathered, at Company’s discretion,
the Company may contact the Customer and request at any time resubmission of documents and the
provision of additional Clarifications, information, and documents.
3.2. Ongoing monitoring is based on a quantitative or qualitative review of the Customer's activity.
3.3. Identification of Politically Exposed Persons:
3.3.1. The Company must always establish whether the Customer (its manager / representative) and
the Beneficial Owner are Politically Exposed Persons.
3.3.2.In order to establish whether the Customer (its manager / representative) and the Beneficial
Owner are Politically Exposed Persons, the Company shall perform the following steps when
establishing the identity of the Customer and the Beneficial Owner:
3.3.2.1. Request the Customer or its representative to go through the KYC procedure, where the
Customer or its representative is asked to provide information about the political exposure of the
Customer (its manager / representative) and the Beneficial Owner:
3.3.2.2. Verify the information received from the Customer and its representative against available
databases. The Company shall carry out such screening in databases owned or operated by third
parties.
3.3.2.3. If it is determined that the Customer or the Beneficial Owner is a Politically Exposed Person,
enhanced Customer and Beneficial Owner due diligence shall be carried out.
3.3.2.4. The determination whether the Customer and the Beneficial Owner is a Politically Exposed
Person must be made prior to the completion of the Customer due diligence procedure.

4. MONITORING OF TRANSACTIONS

4.1. The Company's Customers must complete Company’s identity verification process before trading.
After verification is completed, the Customer consents to transaction monitoring, Company analyses
the Customer's transactional patterns.
4.2 The Company relies on data analysis as a risk-assessment and Suspicious activity detection tools.
These tools perform a variety of compliance-related tasks, including capturing data, filtering, record-
keeping, investigation management, and reporting.
4.3 In connection with the Policy, the Company will:
1. monitor all transactions. The Company reserves the right to ensure that transactions of
Suspicious nature are reported to the proper law enforcement:
2. request the Customer to provide any additional information and documents in case of suspicious
transactions;
3. suspend or terminate Customer’s Account when the Company has a reasonable suspicion that
such Customer is engaged in illegal activity.
4.4. The above list is not exhaustive, and the Compliance Officer will monitor Customers’ transactions
on a regular basis to define whether such transactions are to be reported and treated as suspicious.
4.5. The Company shall carry out continuous monitoring of the Customer’s Business Relationship and
operations / transactions to ensure that the Business Relationship and operations / transactions are
consistent with the Company’s knowledge of the Customer, its business, the nature of risk and the
source of funds.

5. LIMITATIONS AND DENIAL OF SERVICE
5.1. Based on the information provided, the Company reserves the right, at its sole discretion, to deny
Customers access to its services without notice. If the Company determines that any information about
the Customer obtained in accordance with the described procedure is false, insufficient or included in
a list of sanctions, the Company may, at its discretion, either refuse/terminate the registration of such
Customer account or require re-verification of the documents and information provided by the relevant
Customer.
5.2. In the event that the Company receives information that a Customer Or account is maintained under
a false name, the Company has the full right to terminate and block such account immediately and
without prior notice to the Customer concerned.
5.3 The Company also reserves the right to continuously verify the identity of Customers, especially in
Cases of unusual and suspicious activity or if the Company doubts the adequacy or reliability of
previously received Customer identification data. In addition, the Company has the right to require up-
to-date documents from Customers, even if they have already passed an identity check in the past.
5.4. The Company reserves the right to terminate a Customer Account, restrict and/or prevent access
to its online platform, or report the activities of any Customer to the appropriate law enforcement
authorities if it suspects illegal activity.

6. SENSITIVE PERSONAL INFORMATION

6.1. Sensitive personal information is collected, shared and stored securely in accordance with the
Company's Privacy Policy and the General Data Protection Regulation (GDPR).
6.2. Personal data, documents and information are stored for a period of 5 years after termination of
the business relationship, subject to compliance with the requirements for the protection of personal
data in accordance with the Privacy Policy.
7. TERMINATIONS OF TERMS AND BUSINESS

7.1. The Company may refuse to perform operations/transactions if the Customer:
7.1.1. avoids providing the information requested by the Company within the deadlines set by the
Company;
7.1.2. does not fulfill its contractual Obligations specified in the agreement;
7.1.3. does not provide the data requested by the Company to confirm his identity; or provides untruthful
or incomplete information;
7.1.4. tries to open an anonymous account or open an account for a non-existent person;
7.1.5. is suspected of being involved in ML/CTF activities, and the process of further verification raises
the suspicion that his further activities may be transferred to law enforcement agencies.
7.2. The Company may also refuse to perform operations/transactions:
7.2.1. the rules for maintaining relations with a cloud bank or with a bank that allows the use of its
accounts are violated:
7.2.3. The Company cannot ensure compliance with the requirements set out in its Policy;
7.2.4. the identity of the Customer has not been confirmed or there is reason to believe that it has been
faked;
7.2.5. operations/transactions may contradict and/or violate international financial sanctions or other
restrictive measures.
8. AMENDMENTS AND CHANGES TO THE POLICY

8.1. The Company may make amendments and changes to the Anti-Money laundering policy by posting
the revised version of the document on the Website. If the Customer do not agree with any such
modification, the Customer should close the Account and cease using the Website, Platform and the
Services.
8.2. The Policy is reviewed and updated periodically, but not less than once a year, or in case of
significant events. Copies of the most up-to-date version of the policy are always made available on the
Website.