This is the Anti-Money Laundering and Counter-Terrorism Financing Policy (referred to as the AML Policy) of Landix EOOD, a company that operates a platform for the purchase, sale, and exchange of cryptocurrencies - https://www.altcoins.bg/.

Landix EOOD is a limited liability company registered under the laws of the Republic of Bulgaria with UIC: 205491943 and registered address at 2 Ivan Rilski St., Floor 2, Apt. 2, Varna.

Landix EOOD, referred to as the "Company" for brevity, includes its owners, directors, investors, employees, or other related parties. The terms "User," "You," and "Your/Yours" refer to the User of the cryptocurrency trading platform owned by Landix EOOD.

The Company adheres to strict rules to combat money laundering and terrorism financing, as governed by local and international laws and regulations, to prevent any illegal or criminal activities and any potential involvement of the Company in such activities. Accordingly, Landix EOOD implements this policy in compliance with the Anti-Money Laundering Measures Act (ZMiP).

The Anti-Money Laundering and Counter-Terrorism Financing Policy is mandatory for Users to follow. Users are obligated to read, review, understand, and agree to the terms below before using or benefiting from any of the Company’s services.

Definitions

"Applicable Laws" refer to the laws in effect at the time in the territory where the Company operates.

 

"Identification Document(s)" refers to: National ID cards, passports, and any other official identity document; documents verifying the registered address of an individual or legal entity, such as, but not limited to, a bank statement or utility bill; or other documents that may be specified and requested by the Company.

 

"Politically Exposed Person (PEP)" is an individual who performs or has been entrusted with the following prominent public functions in the Republic of Bulgaria, another EU member state, or a third country: heads of state, heads of government, ministers, deputy ministers, or assistant ministers; members of parliaments or other legislative bodies; members of constitutional courts, supreme courts, or other high-level judicial bodies whose decisions are not subject to further appeal except in exceptional circumstances; members of courts of auditors; members of governing bodies of central banks; ambassadors and heads of diplomatic missions; senior officers in the armed forces; members of administrative, management, or supervisory bodies of state-owned enterprises and companies wholly owned by the state; mayors and deputy mayors of municipalities, mayors and deputy mayors of districts, and chairs of municipal councils; members of the governing bodies of political parties; heads and deputy heads of international organizations, members of management or supervisory bodies of international organizations, or individuals performing equivalent functions in such organizations.

 

"Persons Associated with a Politically Exposed Person" are individuals in the following relationships with a PEP: spouses or persons living in de facto cohabitation on a marital basis; first-degree descendants and their spouses or persons with whom they live in de facto cohabitation; first-degree ascendants and their spouses or persons with whom they live in de facto cohabitation; second-degree collateral relatives and their spouses or persons with whom they live in de facto cohabitation; any individual known to be a joint beneficial owner with a PEP of a legal entity or other legal formation or who has other close commercial, professional, or business relationships with a PEP; any individual who is the sole owner or beneficial owner of a legal entity or other legal formation known to have been established for the benefit of a PEP.

 

"Sanctions Lists" are lists of individuals, legal entities, and entire countries involved or suspected of involvement in illegal and criminal activities. Such lists are provided, for example, by OFAC, the EU, the UN, etc.

 

"Beneficial Owner" refers to: an individual who directly or indirectly owns a sufficient percentage of shares, stakes, or voting rights, including through bearer shares, pursuant to § 2, Para. 1, Item 1 of the Supplementary Provisions of the ZMiP; an individual exercising control as defined in § 1c of the Supplementary Provisions of the Commercial Act; an individual exercising decisive influence in decisions regarding the appointment of management and supervisory bodies, transformation, termination of activities, and other matters of significant importance to the activity, pursuant to § 2, Para. 3 of the Supplementary Provisions of the ZMiP; an individual exercising ultimate effective control through the exercise of rights via third parties, including but not limited to rights granted by proxy, contract, or other transactions, as well as through other legal forms enabling decisive influence via third parties, pursuant to § 2, Para. 4 of the Supplementary Provisions of the ZMiP; a founder, trustee, protector, beneficiary, or person in whose primary interest a trust is established or managed, or an individual ultimately exercising control over the trust through direct or indirect ownership or other means, or an individual holding a position equivalent or similar to those mentioned above; an individual on whose behalf and/or for whose account a transaction, deal, or activity is carried out and who meets at least one of the conditions specified in § 2, Para. 1, Items 1–3 of the Supplementary Provisions of the ZMiP; an individual holding a senior management position when no other beneficial owner can be identified.

 

User Verification

The Company applies client identification provisions through identity verification for every individual wishing to conduct fiat currency transactions on the platform operated by the Company and for the beneficial owners of any company/organization wishing to become a client of the Company as a legal entity. Following established rules, regulations, and procedures related to the Know Your Customer (KYC) concept, the Company requires identification information and documentation that the User must provide. For the purpose of verifying the identity of any User, the Company may rely on appropriate and licensed third-party service providers to authenticate identification documents and other data provided by the User. Any client who has passed the KYC procedure may conduct fiat currency transactions on the platform operated by the Company only if they use payment services in their own name.

Identification of Individuals

Every individual wishing to conduct transactions on the platform operated by the Company must be identified by collecting the following information: full name; date and place of birth; personal identification number; official identification document (ID card and international passport) containing a photo, nationality, date of birth, and personal identification number issued by the respective country; residential address; any citizenship held by the individual; information about professional activities and the reasons for planned or executed transactions; source of funds to be used for trading on the platform; expected volume of purchases and sales on a monthly basis. The following checks are performed via an automated solution: identity document verification; real-time selfie; facial match with the identity document photo; AML screening (international sanctions lists, PEP lists, watchlists, and negative media). For individuals whose trading volume over the past 120 days exceeds the equivalent of 15,000 EUR (29,337.45 BGN), information on the source of funds is also required (completion of a corresponding declaration and submission of a supporting document demonstrating the stated origin of the funds).

The verification procedure for individuals also applies to the managers of legal entities wishing to use the services provided by the Company through a corporate profile. In this regard, the manager must create a personal profile on Altcoins.bg and complete the KYC procedure for individuals.

Identification of Legal Entities and Beneficial Owners

General information about the identity of any legal entity must undergo a verification process before using the Company’s services and must be identified by collecting the following information: name; registration number in a national register; legal form in accordance with the local legislation of the country where the legal entity is registered; registered office address and management address; a document verifying the company’s address (bank statement, electricity/water bill, or other utility bill) not older than 3 months; information about the company’s activities, licenses, registrations, shares and their trading, clients, etc., and the reasons for planned or executed transactions in the form of a questionnaire; information about the company’s ownership structure; articles of incorporation/partnership agreement; latest annual financial statement; declaration identifying the beneficial owner.

Beneficial Owners

The information that the User must provide about the beneficial owners of the legal entity includes: the full name of each owner with at least 25% control over the company; an official identification document (such as an ID card and international passport) containing a photo, nationality, date of birth, and personal identification number issued by the respective country. If the legal entity is owned by another entity, the Company also requires: an extract from the commercial register; articles of incorporation/partnership agreement; a document verifying the company’s address (bank statement, electricity/water bill, or other utility bill); information about the ownership structure (chart).

Additional Verification Measures

For legal entities whose trading volume over the past 120 days exceeds the equivalent of 15,000 EUR (29,337.45 BGN), information on the source of funds is also required (completion of a corresponding declaration and submission of a supporting document demonstrating the stated origin of the funds).

Screening Against International Sanctions Lists

The Company is prohibited from conducting transactions with individuals, companies, and countries listed on international sanctions lists. Therefore, the Company screens its Users against relevant lists from the UN, European Union, UK Treasury, U.S. Office of Foreign Assets Control (OFAC), and other sanctions lists.

PEP Screening

To identify politically exposed persons among its Users, the Company does not rely solely on declarations provided by Users but also screens all individual account holders, all beneficial owners of corporate account holders, and any person with access to a corporate account against various domestic and international PEP lists.

Restrictions and Denial of Service

Based on the provided information, the Company reserves the right, at its sole discretion, to deny Users access to its services without prior notice. If the Company determines that any information about a User obtained through the described procedure is false, insufficient, or included in a sanctions list, the Company may, at its discretion, either refuse/terminate the registration of such a User account or require re-verification of the documents and information provided by the respective User. If the Company receives information that a User or account is maintained under a false name, the Company has the full right to terminate and block such an account immediately without prior notification to the respective User.

Landix EOOD also reserves the right to continuously verify the identity of Users, particularly in cases of unusual or suspicious activity or if the Company doubts the adequacy or accuracy of previously obtained User identification data. Furthermore, the Company may request updated documents from Users, even if they have already passed identity verification in the past. The Company reserves the right to terminate a User account, restrict and/or prevent access to its online platform, or report to the relevant law enforcement authorities the activities of any User if there is suspicion of illegal activity.

Sensitive Personal Information

Sensitive personal information is collected, shared, and stored securely in accordance with the Company’s Privacy Policy and the General Data Protection Regulation (GDPR).

Storage of Personal Information

Personal data, documents, and information are stored for a period of 5 years after the termination of the business relationship, in compliance with personal data protection requirements as per the Privacy Policy.

Risk-Based Approach

The Company is committed to adhering to the highest standards and therefore adopts a risk-based approach. As a result, the Company reserves the right to classify Users into different risk categories based on the following factors: place of residence, citizenship, and/or registered office of the person involved in the transaction; parameters characterizing the person involved in the transaction; economic activity and behavior of the person involved in the transaction. Landix EOOD maintains the confidentiality of risk categorization and may change a User’s categorization at any time, considering various factors. While Users are not entitled to request disclosure of information regarding categorization, the Company may disclose risk categorization data to the competent law enforcement authority if it determines that a particular User has executed or is likely to execute a suspicious transaction.

Changes

This Anti-Money Laundering and Counter-Terrorism Financing Policy may be periodically reviewed and amended. Users are required to periodically visit the Company’s website and review the terms and any changes to them. Continued use of the Company’s services by a User constitutes agreement with all amendments to the policy. If you have questions about the Company’s Anti-Money Laundering and Counter-Terrorism Financing Policy, please contact us at support@altcoins.bg.