Anti-Money Laundering and Know Your Customer Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the guidelines and procedures implemented by COEX (Coin Experts EOOD), a company incorporated in the province of Bulgaria with the company number 207144090.

The company's registered address is located at Sofia 1797, Studentski District, zh.k. Musagenitsa, 91B, entr.A, 14.

COEX is fully committed to achieving full compliance with applicable laws of the Bulgaria and European Union (EU), and international regulations, with the aim of preventing money laundering and terrorist financing.

In addition to adhering to legal requirements, COEX has established internal policies and guidelines to create a comprehensive framework for conducting due diligence on clients, monitoring transactions, and reporting any suspicious activities.

Customer Due Diligence (CDD) of COEX aims to ascertain the client's identity and establish a comprehensive client profile, facilitating the identification of any unusual behavior.

If such behavior raises suspicions of money laundering or terrorist financing, COEX thoroughly investigates and promptly reports to the National Revenue Agency of Bulgaria (NRA).

The CDD process encompasses the following measures:

During customer registration, COEX gathers and verifies the necessary information and documentation to establish the customer's identity.

To ensure the validity and authenticity of identification documents, COEX employs document verification procedures. Customer identification and verification are conducted based on a risk-based approach, taking into account factors such as the customer's profile, transaction history, and the jurisdiction of the Client.

COEX authenticates a person's identity by consulting an official photo identification document issued by the government.

COEX initiates and/or continues business relationships only with clients falling within the low to medium risk categories.

Ongoing monitoring is a procedural method devised and employed by COEX to systematically review all the information gathered about clients with whom the Company has established a business relationship.

In cases where enhanced due diligence is deemed necessary, additional verification procedures and information collection from customers are conducted. Periodic reviews of customer accounts and updated due diligence are performed to ensure ongoing compliance with regulations.

COEX provides training to its employees to promptly recognize and report any suspicious activities. In adherence to legal obligations, any identified suspicious activity is promptly reported to appropriate regulatory and law enforcement authorities.

Regular internal and external audits are conducted by COEX to assess the effectiveness and compliance of its AML and KYC procedures. By implementing these measures, COEX strives to establish a comprehensive understanding of its clients, monitor their activities, and fulfil its obligations in combating money laundering and terrorist financing.

To comply with applicable laws and internal guidelines, COEX refrains from providing services or engaging in business activities with individuals or entities based in countries that are listed under various sanctions, including United Nations Security Council Sanctions List; FATF list of High-Risk Countries and Non-Cooperative Jurisdictions; EU Consolidated Sanctions List; National List under LMFT.

Additionally, COEX reserves the right to exclude jurisdictions at its discretion, with the possibility of periodic amendments the risk posed by an individual generally involves considering their economic activity and/or source of wealth. A client with a single source of consistent income poses a lower risk of ML/FT compared to a client with multiple income sources or irregular income streams.

COEX uses transaction monitoring tools to identify and analyze potentially suspicious activities. These tools continuously monitor transactions, account behavior, and patterns that may be indicative of money laundering or terrorist financing.

In the event that suspicious activity is identified, COEX will report it to NRA pursuant to the laws of Bulgaria and relevant international regulations.

COEX keeps detailed records containing customer identification information, transaction data, and communications for a minimum of 5 years, unless longer retention is mandated by applicable law, regulation, or directive.

These records are securely stored and easily accessible for the purpose of audits and regulatory requirements.

Training methodologies of COEX are provided to the staff and encompass independent learning, informational sessions, in-person meetings, classroom sessions, conferences, and on-the-job training with provided guidance .

This training ensures that the employees are fully aware of their responsibilities and equipped to effectively identify and report any suspicious activities.

A designated Compliance Officer is appointed by the COEX to oversee the implementation and adherence to AML and KYC policies. The Compliance Officer ensures that the COEX remains updated with regulatory requirements and promptly reports any concerns or suspicions to the NRA.

COEX regularly undergoes independent audits of its AML/CFT program to evaluate its efficacy, identify areas for enhancement, and ensure adherence to regulations. The findings from these audits are thoroughly reviewed by management, and appropriate measures are taken to rectify any identified shortcomings.

When entering into business relationships with third parties, COEX requires these parties to adhere to the same AML and KYC processes as outlined in this Policy and guided by the Compliance officer. Ongoing monitoring and periodic reviews are conducted by the the COEX to assess the compliance of these third parties with AML and KYC regulations.

This Policy undergoes periodic evaluations by COEX to ensure its effectiveness and compliance with evolving regulations and best practices. Updates and amendments will be implemented as necessary. The effective date signifies the commencement of the latest version of this policy. Any changes to the effective date will be clearly indicated at the beginning of this document.