AML/KYC Policy

1. Introduction

Clearex (“the Company”) operates an over-the-counter (OTC) cryptocurrency exchange service. This AML/KYC Policy outlines the procedures and controls implemented to prevent money laundering, terrorist financing, and other financial crimes in compliance with EU Directive 2015/849 (AMLD5), Latvian Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, and applicable regulations.

2. Customer Identification Program (CIP)

All customers must be identified before conducting transactions. Verification levels depend on the transaction amount:

3. Customer Due Diligence (CDD)

• All customers are screened against international sanctions lists (EU, UN, OFAC)
• Politically Exposed Persons (PEPs) are subject to enhanced due diligence
• Transaction monitoring is performed on all exchanges to detect suspicious patterns
• Source of funds verification for transactions exceeding €5,000
• Ongoing monitoring of customer activity and periodic review of risk profiles

4. Transaction Monitoring

The Company monitors all transactions for suspicious activity, including but not limited to:

• Structuring — splitting large amounts into smaller transactions to avoid thresholds
• Transactions involving high-risk jurisdictions
• Unusual transaction patterns inconsistent with customer's stated purpose
• Transactions from wallet addresses flagged by blockchain analytics tools
• Rapid succession of exchanges within a short timeframe

5. Blockchain Analytics

All incoming cryptocurrency transactions are screened using blockchain analytics tools. Transactions from wallet addresses associated with known illicit activities, darknet markets, sanctioned entities, or mixer/tumbler services may be rejected or flagged for further investigation.

6. Record Keeping

The Company retains all customer identification data, transaction records, and due diligence documentation for a minimum of 5 years after the business relationship has ended, as required by applicable law. Records are stored securely with encryption at rest and are accessible to competent authorities upon lawful request.

7. Suspicious Activity Reporting

If the Company identifies suspicious activity, a Suspicious Activity Report (SAR) will be filed with the relevant Financial Intelligence Unit (FIU). The Company reserves the right to suspend, freeze, or terminate the account of any customer engaged in or suspected of engaging in illicit activity, without prior notice, as required by law.

8. Prohibited Activities

• Providing false or misleading identification documents
• Using the service for money laundering or terrorist financing
• Operating on behalf of sanctioned individuals or entities
• Structuring transactions to evade verification requirements
• Using mixer/tumbler services to obscure the origin of funds

9. Staff Training

All personnel involved in customer-facing operations receive regular AML/KYC training, including identification of suspicious activities, regulatory obligations, and reporting procedures.

10. Policy Updates

This policy is reviewed and updated at least annually, or more frequently if required by changes in applicable laws and regulations. Customers will be notified of material changes through our website and Telegram channel.