AML Policy

1. Purpose of This AML Policy

This Anti-Money Laundering and Counter-Terrorist Financing Policy explains the principles and controls POLONNE.TRADE applies to identify, prevent, detect, and respond to suspicious or unlawful activity.

Our compliance framework is designed to support applicable anti-money laundering, counter-terrorist financing, sanctions, fraud prevention, and financial crime requirements in the jurisdictions in which our services are legally available.

2. Our AML Commitment

POLONNE.TRADE maintains a risk-based approach to financial crime prevention. We seek to understand our customers, monitor relevant activity, identify unusual transaction patterns, and take appropriate action when potential risks are identified.

3. Know Your Customer (KYC)

Depending on the service, jurisdiction, account activity, or applicable requirements, customers may be required to complete identity verification before accessing certain features.

• Collection and verification of identifying information.
• Verification of identity documents where required.
• Assessment of customer information and account activity.
• Additional verification where elevated risk is identified.
• Periodic or event-driven review of customer information.

Customers are responsible for providing accurate, current, and complete information. Providing false, misleading, fraudulent, or manipulated information may result in account restrictions or termination.

4. Customer Due Diligence

POLONNE.TRADE may perform customer due diligence before or during the relationship with a customer. The scope of due diligence may depend on the customer's risk profile and the services being used.

5. Enhanced Due Diligence

Additional information or verification may be requested when a customer, transaction, jurisdiction, source of funds, or pattern of activity presents increased risk.

• Additional identification or verification information.
• Information concerning source of funds or source of wealth.
• Additional information regarding the purpose of transactions.
• Information concerning business activity or beneficial ownership.
• Additional review of transaction history or account behavior.

6. Transaction Monitoring

Transactions and account activity may be monitored using automated controls, internal reviews, risk indicators, and other appropriate compliance processes.

7. Prohibited Activities

Customers must not use POLONNE.TRADE for unlawful activities or for transactions intended to conceal, disguise, transfer, or facilitate proceeds of crime.

• Money laundering or attempted money laundering.
• Terrorist financing or financing of prohibited organizations.
• Fraud, scams, identity theft, or other deceptive activity.
• Transactions involving sanctioned persons or prohibited jurisdictions.
• Use of accounts to conceal the identity or origin of funds.
• Use of the platform for unlawful or unauthorized purposes.
• Attempts to bypass KYC, AML, transaction, or security controls.

8. Sanctions Compliance

POLONNE.TRADE may apply sanctions screening and other controls to identify potential exposure to applicable sanctions restrictions.

Transactions or accounts may be blocked, rejected, delayed, frozen, or reviewed where sanctions-related concerns are identified or where required by applicable law.

9. Source of Funds and Source of Wealth

Where appropriate, POLONNE.TRADE may request information regarding the source of funds or source of wealth associated with an account or transaction.

Customers must be able to provide truthful and sufficient information when requested. Failure to provide requested information may result in restrictions on relevant services or transactions.

10. Suspicious Activity

Where POLONNE.TRADE identifies activity that may indicate money laundering, terrorist financing, fraud, sanctions violations, or another form of financial crime, the platform may conduct an internal compliance review.

11. Account Restrictions and Freezes

POLONNE.TRADE may temporarily or permanently restrict an account, transaction, withdrawal, deposit, or other service where this is reasonably necessary for security, fraud prevention, AML, sanctions compliance, legal obligations, or risk management.

• Additional verification may be required.
• Deposits or withdrawals may be temporarily delayed.
• Transactions may be rejected or cancelled where appropriate.
• Accounts may be suspended pending compliance review.
• Accounts may be terminated where permitted or required by law.

12. Third-Party Service Providers

POLONNE.TRADE may work with specialized service providers for identity verification, sanctions screening, blockchain analytics, fraud prevention, transaction monitoring, security, and other compliance-related functions.

Such providers may process relevant information in accordance with applicable agreements, privacy requirements, and their respective security controls.

13. Blockchain and Digital Asset Monitoring

Because blockchain transactions may be publicly traceable, blockchain analytics and transaction-risk information may be used where appropriate to identify potentially suspicious activity, exposure to high-risk addresses, sanctions-related risks, or other indicators.

Blockchain transaction characteristics may form one part of a broader risk assessment and do not necessarily determine the outcome of a compliance review by themselves.

14. Record Keeping

POLONNE.TRADE may retain customer, verification, transaction, and compliance records for periods required by applicable laws, regulations, contractual obligations, security requirements, and legitimate business purposes.

Records may be maintained to support regulatory compliance, investigations, dispute resolution, fraud prevention, auditing, and other lawful purposes.

15. Customer Responsibilities

Customers play an important role in maintaining a compliant and secure financial environment.

• Provide accurate and truthful account information.
• Keep identity and account information up to date.
• Use the platform only for lawful purposes.
• Do not allow another person to misuse your account.
• Do not attempt to bypass compliance or security controls.
• Provide requested information within a reasonable timeframe.
• Report suspected unauthorized or fraudulent activity promptly.

16. AML Compliance Process

Our compliance framework may involve multiple stages depending on the customer's profile and the nature of the activity.

17. Cooperation With Authorities

Where legally required, POLONNE.TRADE may cooperate with competent governmental, regulatory, law-enforcement, judicial, or other authorized authorities.

Information may be disclosed where necessary to comply with applicable legal obligations, lawful requests, court orders, regulatory requirements, or financial crime investigations.

18. Privacy and Data Protection

Personal information collected for AML, KYC, fraud prevention, sanctions screening, or other compliance purposes is handled in accordance with applicable privacy and data protection requirements and our Privacy Policy.

Access to compliance information is limited according to appropriate security and operational requirements.

19. Risk-Based Approach

AML controls are applied proportionately according to identified risk. Higher-risk circumstances may require stronger verification, additional monitoring, transaction restrictions, or enhanced due diligence.

Lower-risk activity may be subject to proportionate controls, while all customers remain subject to applicable legal, security, and compliance requirements.

20. Policy Updates

POLONNE.TRADE may update this AML Policy from time to time to reflect changes in applicable laws, regulations, regulatory guidance, services, technologies, risk controls, or internal compliance procedures.

The latest version published on this page will apply from its stated effective date.