Anti-money laundering and counter terrorist financing policy

  1. The below is a summary of the Anti-Money Laundering and Counter Terrorist Financing Prevention Policy ("AML Policy") of COTI Limited ("Company", "we","us" or "our"). Any questions relating to this policy should be directed to MLRO@COTI.io.
  2. The purpose of this AML Policy is to articulate our commitment to detecting, preventing and reporting attempts to use the Company’s platform (the "Platform") and the digital tokens issue by the Company (the "COTI Tokens") to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, to commit fraud etc. (all activities being "Prohibited Activities").
  3. In the event we suspect that an activity or behaviour in the Platform and/or with the COTI Tokens associated with you ("you", "your" means a contributor and/or a Purchaser as defined in the Terms of Use) may meet the characteristics of Prohibited Activities, we reserve the right to suspend your use of the Platform and freeze any funds in fiat currency and/or COTI Tokens, pending the outcome of an internal investigation, whether with or without prior notice (if at all), in compliance with the applicable laws and regulations. We reserve the right to report any suspicious activities to the police and/or relevant authorities without your knowledge.
  4. The decision of whether a transaction is potentially suspicious as Prohibited Activities shall be made by the Company at its sole and absolute discretion.
  5. In relation to the Prohibited Activities, we have:
    1. Appointed a Money Laundering Reporting Officer;
    2. Adopted a risk based approach towards assessing and managing the money laundering risks to the business;
    3. Adopted a risk-based customer due diligence system and thereunder we obtain identification and proof of address in accordance with the KYC ("know your customer") procedures, which include enhanced due diligence checks in cases that we consider higher risk - the risk factor will be determined at our sole discretion;
    4. Put into place an internal procedure for flagging and reporting suspicious activity;
    5. Collected, and continue to collect, information with the aim of verifying information to serve the "Know Your Client" and "Client Due Diligence" efforts (hereinafter, collectively, "KYC").
  6. If you are a Restricted Territories User you will not be able to participate in the COTI Tokens distribution period and you are not allowed to hold any COTI Tokens. "Restricted Territories User" means, citizen, resident of, a person located or domiciled in, or any corporation or partnership created or organized in or under the laws of: (1) the United States of America including its states, territories or the District of Columbia; (2) Israel; (3) Bosnia Herzegovina; (4) Syria; (5) Iran; (6) Ethiopia; (7) Uganda; (8) North Korea; (9) the People’s Republic of China; or (10) any other jurisdiction We may add or delete from time to time in the light of the relevant watch lists and as per Our sole discretion.
  7. During your registration on the Platform, you will be asked to enter the address of the digital wallet you will use for the purchase of the COTI Tokens. Any attempts to send funds from a different address or directly from an exchange (such as Coinbase, Kraken, Poloniex, etc.) during the COTI Tokens distribution period may result in an inability to purchase COTI Tokens.
  8. As part of our AML Policy, you understand that while you agree to use the Platform, you are also prepared to provide, prior to any purchase of COTI Tokens, any documentation which we find relevant in order to serve our KYC and AML policies, including (but not limited to): full name, address, contact details such as (but not limited to) mobile phone number and email, date of birth, payment reference (such as, but not limited to, SWIFT or credit card picture with first 4 and last 4 digits where your name is clearly seen, passport, ID, driving license, utility bill, bank statement and references in connection with your source of funds.
  9. In addition to the above, in case you are an entity, you understand that while you agree to use the Platform, you are also prepared to provide, prior to any purchase of COTI Tokens, any documentation which we find relevant in order to serve our KYC and AML policies, including (but not limited to):
    1. Certificate of incorporation of any legal person associated with your activity;
    2. Memorandum & Articles of Association, by-laws, or any similar governing documents of all legal persons associated with your activity;
    3. List of shareholders (including ownership structure) and directors and signatories of all legal persons associated with your activity;
    4. Certificate of Incumbency stating the registered address, share capital, shareholder(s) and the person/s authorized to represent the legal person (NOTARIZED and APOSTILLED) of any legal person associated with your activity; and
    5. Any additional information we may find valid for assessing the risk of providing you with our services.
  10. As part of our AML Policy, you understand that while you agree to use the Platform, you are also prepared to provide, prior to any purchase of COTI Tokens, proof regarding the source of wealth and/or funds of any individual associated with your activity;
  11. If you are acting on behalf of a legal person you will be required to provide Us with valid power of attorney and send us the aforementioned KYC documents with a company stamp and certified as a true copy of the original by a lawyer, certifying officer or a Notary public.
  12. We require the KYC documents to be sent to us in high quality colour format. We reserve the right to reject any documents which do not comply with the above.
  13. We reserve the right to require additional information at any time to verify your identification and any further information that we may require, and to use third parties in order to identify and investigate the information you provided and other information with regards to you (such as, but not limited to, online verification, political exposed person identification etc.).
  14. We may also disclose any and/or all of the KYC documents to any relevant authority and/or institution in order to examine, inter alia, your status concerning bankruptcy, reputation checks and criminal records and/or in order to comply with AML laws, regulations, rules or anything related thereto.
  15. We restrict certain jurisdictions, type of businesses and certain individuals from using the Platform and purchasing and holding the COTI Tokens. The AML Policy is not a substitute for your need to comply, in full, with the applicable laws and regulations in connection with your business conduct, personal characteristics and legal status. We do not offer any consultancy in connection with your need to comply with the applicable laws and regulation.
  16. We may change this policy, at our own discretion, from time to time in compliance with the dynamic applicable laws and regulation framework, without notice.

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