Anti-Money Laundering Policy

1. Introduction and Purpose

POLAND-BUSINESS L.T.D ("Company," "we," "our," or "us") is committed to preventing the use of our Volt platform for money laundering, terrorist financing, or any other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to detect and prevent such activities.

2. Scope

This policy applies to all users of the Volt platform, all employees and contractors of POLAND-BUSINESS L.T.D, and all transactions processed through our services.

3. Know Your Customer (KYC) Procedures

We implement KYC procedures to verify the identity of our users:

• Payment card verification through our payment processor
• Additional identity verification may be required for high-value transactions
• Executor applicants undergo enhanced verification including identity documents

4. Transaction Monitoring

We monitor transactions for suspicious activity, including:

• Unusual transaction patterns or volumes
• Multiple purchases from different cards to the same account
• Transactions from high-risk jurisdictions
• Rapid credit purchases followed by immediate usage or refund requests
• Structuring transactions to avoid verification thresholds

5. Risk Assessment

We assess money laundering and terrorist financing risks based on:

• Customer risk factors (transaction history, geographic location)
• Product and service risk factors
• Delivery channel risks (online platform)
• Geographic risks based on international AML standards

6. Suspicious Activity Reporting

When suspicious activity is detected, we will:

• Conduct an internal investigation
• File Suspicious Activity Reports (SARs) with relevant authorities where required
• Suspend or terminate accounts involved in suspicious activity
• Cooperate with law enforcement investigations

7. Sanctions Compliance

We screen users and transactions against applicable sanctions lists, including:

• OFAC (Office of Foreign Assets Control) sanctions lists
• EU consolidated sanctions list
• UN sanctions lists
• Other applicable national and international sanctions programs

8. Record Keeping

We maintain records of:

• Customer identification information for at least 5 years after account closure
• Transaction records for at least 5 years after the transaction
• Suspicious activity reports and investigation records
• AML training and compliance records

9. Employee Training

All employees receive AML compliance training, including:

• Recognition of suspicious activities and red flags
• Reporting procedures and escalation protocols
• Legal obligations and consequences of non-compliance
• Annual refresher training and updates on regulatory changes

10. Prohibited Activities

The following activities are strictly prohibited on our platform:

• Using the platform for money laundering or terrorist financing
• Processing payments for illegal goods or services
• Using stolen or fraudulent payment methods
• Creating multiple accounts to circumvent controls
• Providing false or misleading information during verification

11. Policy Updates

This AML policy is reviewed annually and updated as necessary to reflect changes in regulations, business practices, and risk assessments. Material changes will be communicated to users.

12. Contact Us

To report suspicious activity or for compliance inquiries, contact our Compliance team at compliance@volt.equipment.