AML Policy

1. Summary of applicable AML, CTF, and CPF measures
Cloverum strictly adheres to applicable national legislation and international standards in the fields of Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Counter-Proliferation Financing (CPF).
We have implemented internal policies and procedures that reflect our actual operational processes. This is a public summary of our AML/CTF/CPF Policy. Full internal procedures may be disclosed to competent authorities or institutional partners upon request.
2. Our Business Activities
The Company provides the following services:
• Transfer of virtual assets;
• Exchange between virtual assets and fiat currencies;
• Custody and administration of crypto-assets and private cryptographic keys.
Virtual asset services are considered high-risk due to their inherent characteristics.
According to the Financial Action Task Force (FATF), virtual assets pose significant money laundering and terrorist financing risks because of:
• their cross-border nature (transactions can be rapidly transferred across jurisdictions);
• their speed and irreversibility (making transactions hard to intercept or reverse);
• anonymity and pseudonymity, which hinder the identification of users and beneficial owners.
FATF specifically requires that Virtual Asset Service Providers (VASPs) implement robust customer due diligence and transaction monitoring procedures to address these risks and prevent misuse of the financial system.
3. Compliance Measures
Our AML/CTF/CPF compliance program includes the following key elements:
• Customer Due Diligence (CDD), including Enhanced Due Diligence (EDD) in higher-risk situations (e.g., for Politically Exposed Persons (PEPs) or customers from high-risk jurisdictions);
• Risk-based assessment of customers and their transactions based on source of funds, geographical exposure, and behavioral patterns;
• Ongoing transaction monitoring to detect and report suspicious activity;
• Recordkeeping and data availability for competent authorities, in accordance with legal requirements;
• Cooperation with the Financial Intelligence Unit (FIU), including participation in guidance sessions, workshops, and training for management and compliance staff;
• Ongoing staff training on AML/CTF/CPF obligations, red flags, and internal procedures.
4. Restricted Jurisdictions, Assets, and Activities
We do not onboard clients from jurisdictions subject to international sanctions or included in the FATF blacklist (e.g., Iran, North Korea, Myanmar).
We do not engage in transactions involving privacy tokens or other non-transparent assets.
We do not accept or send tokens to/from high-risk sources, such as:
• blockchain mixers;
• darknet markets and related services;
• addresses linked to terrorist financing, child exploitation, or other criminal activity;
• addresses subject to sanctions or law enforcement monitoring.
Cloverum reserves the right to suspend, block, or reject any transaction deemed high-risk, at its sole discretion, to ensure full compliance with obligations.
We also do not work with uncooperative clients, and expect the same high level of commitment to AML/CTF/CPF standards and regulatory compliance.
As part of our onboarding and ongoing monitoring, we assess:
• the effectiveness of the client's own AML controls,
• the nature of their customer base, and
• the experience and qualifications of their compliance officer.
5. Governance and Accountability
A designated Money Laundering Reporting Officer (MLRO) is responsible for the implementation and oversight of Cloverum's AML/CTF/CPF framework.
This individual is a trained and certified professional, formally approved by the relevant authorities.
6. Transparency
This document provides a public summary of Cloverum's internal AML/CTF/CPF policy.
The full policy, including detailed procedures and internal controls, is considered confidential and may be shared with competent authorities upon formal request.