1. Purpose

This Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Policy iterates our commitment to preventing the use of our crypto platform for money laundering, terrorist financing and other illicit activities, and also acting according to local and international law.

2. Scope

This policy applies to all individuals and organizations acting on behalf of Dart Software Varieties Limited (“Dart”). This includes employees, contractors, and agents of Dart working on behalf of Dart – jointly referred to as “Dart representatives”. The Policy also applies to all customers and users of our platform. The Executive Director and Financial Manager are both, jointly as well as individually, responsible for the execution of this Policy.

3. Risk-Based Approach

We have implemented a risk-based approach to AML/CFT compliance, which means that we assess the risks posed by our customers and transactions and apply appropriate measures to mitigate those risks. We have identified the following risk factors that may affect the risk of our platform being used for money laundering, terrorist financing, or other illicit activities:

• Nature of the customer, including their business or occupation
• Jurisdiction of the customer
• Type and size of transactions
• Payment methods used
• Source of funds or wealth
• Type of cryptocurrency involved

Based on these risk factors, we have developed a risk assessment framework that includes customer due diligence (CDD) measures, ongoing monitoring, and reporting of suspicious activities.

4. Know Your Customer (KYC)

We perform KYC on all customers before allowing them to use our platform. The level of KYC performed depends on the customer’s risk profile, as determined by our risk assessment framework. KYC measures may include:

• Verification of the customer’s identity using government-issued identification documents
• Verification of the customer’s address using utility bills or other reliable sources
• Identification and verification of the beneficial owner of the customer, if applicable
• Enhanced due diligence measures for high-risk customers, such as politically exposed persons (PEPs)

We also perform ongoing monitoring of customer transactions and activities to detect any suspicious behaviour or transactions.

5. Internal Controls, Monitoring and Revisions

Dart assures that its books, records and accounts are maintained correctly and accurately at all times reflecting every transaction, invoice and document, to facilitate anti-corrupt behaviour and increase transparency. The Financial Manager reports the status of Dart’s financial accounts to the Managing Director monthly and annually, with the technical support of an external Accounting firm. This Policy, as well as all, related procedures and systems, will be audited annually to assess its content and effectiveness. If applicable, this Policy may be subject to amendments at any time and in case of changes to legal texts and laws.

6. Record Keeping

We maintain records of all customer due diligence, transactions, and suspicious activity reports (SARs) for at least five years. These records are kept confidential and secure and are only disclosed to law enforcement or regulatory authorities in accordance with applicable laws and regulations.

7. Training and Awareness

Dart ensures that this Policy is communicated to all Dart representatives as an additional attachment to the respective contract/agreement and, additionally, immediately after amendments are made. We provide regular training and awareness to all employees, contractors, and agents on AML/CFT policies and procedures. This training includes information on identifying and reporting suspicious activities and the importance of complying with AML/CFT regulations.

8. Reporting of Suspicious Activities

We have procedures in place for reporting suspicious activities to relevant law enforcement or regulatory authorities. Any employee, contractor, or agent who suspects or becomes aware of any suspicious activities must report them to the designated AML/CFT officer.

9. Misconduct and Sanctions

Any violation of the terms in this Policy by any Dart representative may be subject to disciplinary action, and in extreme cases to immediate termination of employment and/or a claim for payment of a damage. The same applies to any Dart representative knowing about any past or potential violations and failing to report those accordingly. If employees and affiliates knowingly deceive and obstruct investigations, their action may be subject to disciplinary proceedings, such as termination of the contract and discharge and/or paying a penalty fine.  

10. Other Dart Policies

This Policy is furthermore complementary to all other existing Dart policies and does not interfere with any of their contents.

11. Conclusion

Dart is committed to maintaining a robust AML/CFT compliance program that effectively prevents the use of our platform for illicit activities. We regularly review and update our policies and procedures to ensure that they remain effective and compliant with applicable laws and regulations.