Introduction

WhiteBIT Kazakhstan's Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) and Know Your Customer (KYC) policies (hereinafter referred to as the "AML/CFT Policy") are designed to identify, prevent, and mitigate potential risks of the WhiteBIT.KZ (WhiteBIT Kazakhstan) cryptocurrency exchange platform being involved in any illegal, fraudulent, or otherwise prohibited activities in applicable jurisdictions.

WhiteBIT Kazakhstan is committed to strictly adhering to Know Your Customer (KYC) and AML/CFT laws and regulations, affirming our commitment to avoiding intentional violations of KYC and AML/CFT policies. Within the scope of reasonable oversight, WhiteBIT Kazakhstan will implement the necessary measures and technologies to provide inherently safe and secure services, thereby maximizing protection against financial losses due to money laundering.

Our Know Your Customer (KYC) and AML/CFT policies represent a comprehensive framework, incorporating international standards and covering specific KYC and AML/CFT regulations applicable to the relevant jurisdictions.

With our robust compliance infrastructure, WhiteBIT Kazakhstan diligently adheres to regulatory requirements and standards at both the local and global levels, thereby ensuring the robust operational integrity of our Platform, namely:

- Know Your Customer (KYC) and Know Your Business (KYB) obligations, which include identifying the customer (individual or legal entity), the beneficial owners (if any), and the nature and purpose of the business relationship; and

- an obligation to maintain constant vigilance with respect to transactions initiated by the User to detect fraudulent behavior and/or criminal activity by the User. Legislation requires that the intensity of vigilance be adapted to the risk profile of the User or transaction. A suspicious activity report (SAR) must be filed with the competent authorities if there is a suspicion that any User transaction constitutes criminal activity, fraudulent behavior, etc.

WhiteBIT Kazakhstan maintains effective internal procedures, in accordance with international and local regulations/laws, where WhiteBIT Kazakhstan operates legally, to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, as well as to respond appropriately to any form of criminal activity by users of the WhiteBIT Kazakhstan platform *(hereinafter referred to as "Clients", "Users").

Money laundering

Money laundering, as defined by international regulations and Kazakhstani legislation aimed at preventing money laundering and terrorist financing, encompasses the following:

Altering the legal status of digital assets or transferring them with the knowledge that these assets are derived from criminal activity, or by participating in such activity, with the intent to conceal or disguise their illicit origin or to assist any person engaged in criminal activity in evading legal consequences. Furthermore, participating in or colluding with the knowledge or reasonable suspicion that such collusion facilitates the acquisition, retention, use, or control of criminally obtained assets.

Concealing or disguising the true nature, origin, source, location, disposition, movement, ownership, or other rights to property with the knowledge that such property is derived from criminal activity or by participating in such activity.

Acquiring, managing, or using property knowing at the time of acquisition or transfer that such property is derived from criminal activity, or participating in such activity, is an offence. Regardless of any attempt to conceal or disguise the criminal origin of the property, acquiring, using, or possessing such criminal property remains unlawful. Importantly, this offence does not require active participation in the laundering process.

Participation in preparatory actions, an attempt to commit, or complicity in any of the actions set out in paragraphs 1, 2, and 3 of this section is also considered an offense.

Money laundering requires separate criminalization, in addition to the predicate offenses. This means that actions related to concealing the origin of digital assets obtained through illegal activity constitute a standalone offense requiring prosecution independent of the underlying criminal activity.

AML/CFT policy identifies three main stages of money laundering:

Placement: involves introducing illegally obtained funds into the financial system;

Layering: focuses on separating illicit funds from their source through complex financial transactions by blurring the lines of communication, moving funds through multiple accounts, financial transactions, or jurisdictions to disguise their origin.

Integration: reintroducing laundered funds into the legitimate economy without reference to their illegal origin, achieved through investments or purchases that create the appearance of legitimate wealth.

WHITEBIT KAZAKHSTAN COMMITS TO A STRICT ZERO APPROACH TO MONEY LAUNDERING, TERRORIST FINANCING, CORRUPTION AND BRIBERY, TAX EVASION, REGARDLESS OF ANY PREDСATE OFFENCE.

WhiteBIT Kazakhstan is obligated to notify the authorized regulatory authorities (the Financial Monitoring Agency of the Republic of Kazakhstan) no later than one business day after receiving information or raising concerns. This obligation applies when there is information or concerns that assets, regardless of their value, were obtained directly or indirectly as a result of a criminal act or participation in such activity. Similarly, it applies if there is information or we suspect that these assets are linked to terrorist financing, in accordance with international AML standards.

Financing of terrorism

Terrorist financing refers to the intentional provision or collection by any means, directly or indirectly, of funds intended or knowingly used to facilitate terrorist acts. It involves legitimate organizations or individuals providing funds to support terrorist activities or organizations for intellectual, political, or other motives.

Terrorist financing is the process by which legitimate businesses and individuals may choose to provide funding to support terrorist activities or organizations for ideological, political, or other reasons.

WhiteBIT Kazakhstan is obligated to ensure that its users:

are not designated as terrorists/extremists or terrorist organizations;

do not contribute to the financing of terrorist organizations or related activities.

Tax evasion, tax fraud

Tax evasion and tax fraud are deliberate attempts to avoid paying the full amount of taxes owed to the government. They involve deceptive actions aimed at circumventing tax obligations, in whole or in part. Tax fraud requires a deliberate intent to defraud and involves identifiable material elements.

Tax fraud can include:

• deliberate omission or deliberate error in tax returns;
• concealment of taxable amounts;
• organization of bankruptcy for the purpose of tax evasion;
• use of other methods to obstruct tax collection.

Bribery and corruption

Bribery and corruption encompass actions in which a person improperly offers, promises, or provides an undue advantage to influence another person's performance of their duties. This undue advantage, which may take the form of monetary or non-monetary benefits, is intended to induce the recipient to perform, delay, or neglect their duties, thereby acting contrary to the principles of honesty and integrity. Conversely, accepting or seeking such an advantage in the context of one's duties constitutes corrupt practice.

Particular attention should be paid to individuals susceptible to engaging in corrupt practices. In particular, those who use their influence for personal gain commit money laundering when they deposit or use funds obtained through improper means or convert advantages gained through their positions of power into monetary assets.

AML/CFT regulation.

International and domestic legislation governing WhiteBIT Kazakhstan's AML/CFT policy:

- Law of the Republic of Kazakhstan dated August 28, 2009, No. 191-IV "On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism";

- 40 Recommendations of the Financial Action Task Force (FATF) - established in the FATF report of February 6, 1990, in Paris. These recommendations, last updated in February 2023, are aimed at preventing money laundering and combating the financing of terrorism;

- United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances - held in Vienna on December 20, 1988;

- United Nations Convention against Transnational Organized Crime - adopted by UN General Assembly resolution 55/25 on November 15, 2000.

Risk-based approach (RBA)

WhiteBIT Kazakhstan utilizes a risk-based approach in its AML/CFT strategy to manage the risks inherent in its operations, using a standardized risk assessment model to assess the money laundering exposure of its relationships with Users. This approach is tailored to the nature, scale, and complexity of its business activities and includes (where appropriate) an assessment of the geographic scope of its business and the types of products and services received when working with Users.

Using this risk-based methodology, WhiteBIT Kazakhstan consistently identifies and assesses the AML/CFT risks inherent in its operations. Through a comprehensive understanding of these risks, WhiteBIT Kazakhstan can identify vulnerabilities in its operations and implement appropriate AML/CFT measures to effectively mitigate these identified risks.

Using a risk-based approach, WhiteBIT Kazakhstan will:

- identify money laundering risks related to business activity;

- conduct a detailed business risk assessment, paying particular attention to the risk factors described in anti-money laundering regulations;

- conduct a risk assessment of both existing and potential Users;

- develop and implement controls to manage and mitigate the impact of actual and emerging risks;

- monitor controls and improve their effectiveness;

- maintain records of actions taken, including the reasons for identified incidents and User actions.

Customer Due Diligence (CDD)

Customer due diligence (CDD) is key to understanding AML/CFT compliance procedures at WhiteBIT Kazakhstan.

Customer due diligence (CDD) aims to strengthen the financial services sector against exploitation for money laundering or terrorist financing. Obtaining complete information about users and effectively using this data is a fundamental protective mechanism for preventing the laundering of illicit funds.

WhiteBIT Kazakhstan is authorized to conduct thorough CDD and ongoing monitoring to establish the identity of users, identify any third-party involvement, ensure compliance with legal requirements for service provision, and facilitate cooperation with law enforcement and government agencies by sharing available information about users or activities under investigation.

Overview of Customer Due Diligence Measures:

- User identification and identity verification: This involves collecting relevant information to establish the user's identity from reliable and independent sources. This includes obtaining data such as name, address, date of birth, and official identification documents;

- Beneficial owner identification and identity verification, where applicable: If applicable, identifying and verifying the identity of the beneficial owner who ultimately owns or controls the user. This measure ensures transparency regarding ownership and control structures;

- Obtaining information on the purpose and intended nature of the business relationship: Obtaining a clear understanding of the purpose, intended nature, and expected regularity of the business relationship. This includes understanding the types of transactions or activities expected to occur as part of the business relationship;

- Monitoring and ongoing due diligence: Continuously monitoring transactions and user activity to detect any anomalous activity, unusual behavior, or questionable conduct. This includes setting up systems to regularly monitor transactions and implementing mechanisms to initiate further investigation if activity appears irregular;

- Risk assessment, risk profiling, and a risk-based approach: Conducting a risk assessment to evaluate and categorize users based on the level of risk they pose, based on factors such as industry sector, geographic location, and the nature of the transactions conducted. Applying a risk-based approach ensures that resources are appropriately allocated to more vigilantly manage high-risk users while reducing unnecessary burden on low-risk users;

- Legal and Regulatory Compliance: Ensuring that the user complies with all relevant legal and regulatory frameworks, including industry regulations and anti-money laundering laws.

- Enhanced Due Diligence: Implementing additional checks and measures for high-risk users or transactions. This may include requesting additional documentation, obtaining senior management approval for business relationships, or conducting more frequent reviews of high-risk activities;

- Recordkeeping and Documentation: Maintaining comprehensive records of the due diligence processes for all customers, including user information, identity verification documents, risk assessments, and transaction records. This documentation is critical for regulatory compliance and audit purposes;

- Training and Development Programs: Providing regular training opportunities for employees involved in CDD processes to ensure they have the knowledge and tools to effectively perform due diligence procedures. This helps maintain a culture of compliance and vigilance throughout the organization.

- Transaction monitoring systems: Implementation of automated AML/CFT systems, software, and services that continuously analyze and monitor transactions for abnormal activity, unusual behavior, or questionable conduct. These systems use algorithms and thresholds to detect anomalies that may indicate potential money laundering activity.

- Adverse media screening: Conducting a search of various media sources to identify any negative or unfavorable information related to users or beneficial owners. This helps assess the potential risks associated with the individuals or entities involved.

- Politically exposed person (PEP) screening: Screening users to determine whether they are politically exposed persons (PEPs) or persons entrusted with important government functions. This additional screening helps assess the associated risks and apply appropriate due diligence measures.

- Geographic risk assessment: assessing the risks associated with specific geographic locations or jurisdictions. Some regions may pose a higher risk due to weak AML/CFT regulations or a higher prevalence of financial crime, requiring tailored due diligence measures;

- Cooperation and information sharing: engaging in cooperation or partnerships with other financial institutions or government agencies to share information and intelligence on emerging risks or criminal activity, enabling joint efforts to combat financial crime.

WhiteBIT Kazakhstan often requires more than just the user's identity. We require a deeper understanding of the user's business activity. This knowledge is necessary to accurately assess the correspondence between transactions and activities conducted with or through the company and the nature of the user's business. Assessing the correspondence between these transactions and the user's stated business activity is fundamental to ensuring a reliable risk assessment and compliance measures.

Know Your Customer (KYC) and Know Your Business (KYB)

When establishing a business relationship with WhiteBIT Kazakhstan, it is important to understand the expected nature of the user's business activity to determine normal operating patterns. As the relationship develops, any routine transactions conducted by the user are assessed against expected activity. Any deviations or unexplained activity are thoroughly reviewed for potential indicators of money laundering or terrorist financing.

At the beginning of the relationship, personal information is collected, including citizenship, date of birth, and residential address. This data is critical for assessing the risk of financial crime, including anti-money laundering (AML) and countering the financing of terrorism (CTF). In cases involving high-risk transactions, verification of the information provided by the user may be required.

If the user is a legal entity (company), the Know Your Business (KYB) compliance procedure is more stringent and depends on factors such as the company's structure, location, and other relevant aspects. Identification of the company's beneficial owners, authorized representatives, directors, address, and the nature of the business is required.

Sources of funds

Verifying the source of funds, including the payment method, origin, and the party making the payment, is a fundamental aspect of every transaction for WhiteBIT Kazakhstan's compliance with AML/CFT laws and regulations. WhiteBIT Kazakhstan's compliance procedures support a strict practice of ensuring full disclosure of the source of funds at the outset of any user relationship.

Users are expected to confirm the accumulation of funds with documentation, such as statements or evidence of specific transactions, such as inheritances or insurance payments.

Furthermore, WhiteBIT Kazakhstan actively seeks clarification regarding the source of funds for compliance reasons regarding its legal nature. Legitimate sources of funds encompassing a variety of legitimate sources, including:

- Employment-related income: such as wages, bonuses, dividends, and other income arising from employment.

- Pensions: including pension payments and similar income related to retirement.

- Savings and investments: including interest earned on personal savings accounts and income from various investments.

- Asset transaction income: such as proceeds from the sale of property or other lawful dispositions of assets.

- Genuine windfall income: including legitimately earned money from betting, lottery winnings, or similar forms of winning based on luck.

- Inheritances and gifts: legitimately acquired funds received through inheritance or as gifts.

On the other hand, illicit sources of funds include money obtained through terrorism, fraud, bribery, money laundering, etc.

Prohibited business activity.

WhiteBIT Kazakhstan regularly reviews the list of activities identified as prohibited. WhiteBIT Kazakhstan prohibits any transactions related to the following activities:

- Drugs and drug paraphernalia (e.g., narcotics, controlled substances, and any equipment designed for the manufacture or use of drugs);

- Marijuana/cannabis dispensaries and related products and businesses;

- Weapons, ammunition, gunpowder, and other explosives (including fireworks);

- Toxic, flammable, and radioactive materials;

- Pseudo-pharmaceuticals, substances intended to imitate illegal drugs;

- Sexually explicit content, sexual services;

- Pyramid and investment schemes, multi-level marketing schemes, and other unfair, predatory, or deceptive practices;

- Items used for speculation or hedging (e.g., derivatives);

- Credit and collection services;

- Items that violate or infringe any intellectual property rights, such as copyrights, trademarks, trade secrets, or patents, including counterfeit or unauthorized goods;

- Products and services with different legal status in different states;

- Transactions that disclose third-party personal information in violation of applicable law;

- Transactions related to cloud mining;

- Transactions involving sanctioned organizations;

Any other business activity that, in our sole discretion, is beyond our risk appetite.

WhiteBIT Kazakhstan adheres to a strict zero-tolerance policy for transactions involving individuals, organizations, or platforms subject to sanctions and known for engaging in illegal activities. These include, but are not limited to, Garantex, Hydra Market, Tornado Cash, Lazarus Group, ChipMixer, Blender.io, Sinbad.io, Samourai Wallet, Evil Corp, and similar companies. Interaction with any of these sanctioned entities, or similar activity detected by regulators, will result in immediate action, including, but not limited to, account blocking, transaction rejection, freezing of funds, and reporting of information to law enforcement. WhiteBIT Kazakhstan fully complies with international sanctions imposed by international regulators.

Enhanced Due Diligence

WhiteBIT Kazakhstan must apply enhanced due diligence measures based on risk sensitivity in any situation that, by its nature, may pose a higher risk of money laundering or terrorist financing. As part of this process, WhiteBIT Kazakhstan may conclude, in accordance with its risk-based approach, that standard proof of identity is insufficient to assess the risk of money laundering or terrorist financing, and that additional information about a specific User is necessary.

The scope of the additional information requested and any ongoing monitoring conducted in relation to any specific User or category of User will depend on the money laundering or terrorist financing risk that WhiteBIT Kazakhstan assesses the User or category of User as posing.

WhiteBIT Kazakhstan adheres to a policy of conducting enhanced due diligence on all Users, as business is not personal. This includes monitoring all transactions, IP address monitoring, and verification of all crypto wallets used by WhiteBIT Kazakhstan for both deposits and withdrawals. WhiteBIT Kazakhstan continually reviews its enhanced due diligence process, and its Compliance Department prepares a quarterly report to the Board of Directors to assess any issues and update on any potential improvements.

WhiteBIT Kazakhstan also conducts additional due diligence when:

- Working with individuals or legal entities registered in countries designated as high-risk;

- The background and purpose of all complex and unusually large transactions, as well as all unusual transaction patterns that have no apparent economic or legitimate purpose;

- Any account with significant transaction activity;

- Working with users who may be politically exposed persons, sanctioned, or have unfavorable media profiles;

- Monitoring of the extent and nature of business relationships must be enhanced to determine whether these actions or transactions are unusual, suspicious, or criminal.

Politically Exposed Persons (PEP) Check

To ensure WhiteBIT Kazakhstan is aware of any users who may be designated as PEPs or included on a sanctions list, WhiteBIT Kazakhstan verifies all users using independent external verification tools.

A politically exposed person (PEP) is an individual who is or has been entrusted with significant public functions, including:

(a) Heads of State, Heads of Government, Ministers, and Deputy or Assistant Ministers;

(b) Members of Parliament or similar legislative bodies;

(c) Members of the governing bodies of political parties;

(d) Members of supreme courts, constitutional courts, or other high-level judicial bodies whose decisions are not subject to further appeal except in exceptional circumstances;

(e) Members of courts of audit or central bank boards;

(f) Ambassadors, chargés d'affaires, and high-ranking officers of the armed forces;

(g) Members of the administrative, managerial, or supervisory bodies of state-owned enterprises;

(h) Directors, alternate directors, and members of the board of directors, or equivalent function, of an international organization.

No public function referred to in paragraphs (a) to (h) shall be construed as covering officials of intermediate or lower rank.

Family members of a politically exposed person (PEP) include the following:

(a) the spouse or a person considered equivalent to the spouse of the PEP;

(b) the children and their spouses or persons considered equivalent to the spouse of the PEP;

(c) the parents of the PEP. "Persons known to be close associates" means

(d) individuals known to have joint beneficial ownership of legal entities or legal arrangements or any other close business relationship with the PEP;

(e) individuals who have sole beneficial ownership of a legal entity or legal arrangement known to have been created for the beneficial benefit of the PEP.

WhiteBIT Kazakhstan has determined that politically exposed persons (PEPs), their family members, and known close associates of PEPs are at risk, and WhiteBIT Kazakhstan is conducting in-depth due diligence on such clients and may request additional information.

Sanctions policy

In line with our commitment to maintaining robust anti-money laundering and counter-terrorist financing practices and compliance with applicable laws and regulations, as well as international financial sanctions, WhiteBIT Kazakhstan implements a strict sanctions policy regarding the freezing of transactions involving sanctioned entities or suspected sanctions violations, as well as the suspension/termination of the use of our services by Users involved in such activity.

WhiteBIT Kazakhstan takes all necessary measures to ensure that all Users with whom it establishes a business relationship are screened for compliance with relevant notices published by: United Nations (UN) Sanctions; US Consolidated Sanctions; OFAC – Specially Designated Nationals (SDN); EU Financial Sanctions; UK Financial Sanctions (HMT), and others.

WhiteBIT Kazakhstan ensures compliance with all regulatory, legislative, economic, and financial sanctions requirements, and conducts sanctions screening of all Users and third parties prior to the commencement of a business relationship and on an ongoing basis throughout the relationship's lifecycle. WhiteBIT Kazakhstan's sanctions policy strictly prohibits any interaction with Users involved in money laundering or terrorist financing. This applies when WhiteBIT Kazakhstan becomes aware of or suspects potential involvement in such activity, or when the relationship with the User poses an unacceptable level of risk of sanctions.

If WhiteBIT Kazakhstan is unsure about a User's potential financial sanctions status or suspects that a specific User transaction violates financial sanctions, WhiteBIT Kazakhstan will initiate a suspension procedure and apply due diligence measures, including:

- gathers additional information to establish the User's potential involvement in financial sanctions or a potential violation of financial sanctions in a transaction or activity. This includes verifying data, documents, or information from a reliable and independent source;

- obtain additional information about the nature and purpose of the business relationship, transaction, or activity. WhiteBIT Kazakhstan may request additional documentation from the User, such as Proof/Source of Funds or Proof of Transaction Origin, identity documents, request photo/video materials for verification, conduct a viability check, and confirm these materials using reliable and independent sources;

- in cases where there is a risk or suspicion of a violation of the Sanctions Policy, WhiteBIT Kazakhstan will strictly apply Enhanced Due Diligence measures;

- freeze the funds and economic resources of the subject of international financial sanctions and suspend or terminate the User's access to WhiteBIT Kazakhstan products and services;

If, after conducting due diligence, WhiteBIT Kazakhstan confirms that a User is indeed subject to financial sanctions or that such User's transaction or activity violates financial sanctions, or if additional information obtained during due diligence does not allow for a conclusive determination, or if there is a suspicion of a violation of financial sanctions, WhiteBIT Kazakhstan will freeze the funds involved in such transaction and suspend the User, promptly reporting such findings or suspicions to the relevant regulatory authorities.

Furthermore, if, during the course of its due diligence process, WhiteBIT Kazakhstan discovers that a User's transaction or activity is related to a sanctioned entity or other third party associated with sanctions—for example, a deposit from such sanctioned entity or its related third party—the User is fully responsible for such transaction and/or activity, assumes full liability for its execution, subsequent due diligence procedures in relation to the transaction, the potential freezing of funds involved in said transaction, and the subsequent suspension of the User.

High-risk countries

Governments and international organizations publish data on countries whose financial or social systems are likely to pose a high risk of money laundering. The regulations require additional due diligence checks when dealing with individuals or funds originating in these countries. Furthermore, they require that these checks take into account specific deficiencies or issues identified by national or international authorities.

Use of WhiteBIT Kazakhstan products/services is prohibited for citizens and/or residents of the following countries (territories) and jurisdictions*: Afghanistan, American Samoa, US Virgin Islands, Guam, Iran, Yemen, Libya, State of Palestine, Puerto Rico, Somalia, Democratic People's Republic of Korea, Northern Mariana Islands, USA, Syria, Russian Federation, Republic of Belarus, Republic of Sudan, Transnistria, temporarily occupied territories of Georgia, Turkish Republic of Northern Cyprus, Western Sahara, Federal Republic of Ambazonia, Kosovo, South Sudan, Nicaragua, Trinidad and Tobago, Venezuela, Myanmar, and temporarily occupied territories of Ukraine.

*Please note that the above list of prohibited and high-risk jurisdictions is constantly being reviewed by WhiteBIT Kazakhstan in accordance with current laws and regulations, and therefore it is your responsibility to check the latest version available on our website.

Monitoring customer transactions

After user registration, WhiteBIT Kazakhstan conducts comprehensive transaction monitoring procedures. Using automated fraud prevention and risk management systems developed in-house, WhiteBIT Kazakhstan maintains vigilance throughout the entire business relationship.

Control measures include:

- Transaction Monitoring: Continuous monitoring of customer-initiated transactions to identify any that appear unusual, fraudulent, or otherwise criminal, or deviate from typical patterns based on our understanding of the user and the risk profile of the business relationship. This vigilance includes automated and manual transaction monitoring tools using predefined criteria, parameters, and thresholds;

- Sanctions Compliance: Monitoring and assessing transactions involving sanctioned persons or entities against recognized sanctions lists;

- Regular Client File Updates: Periodically updating user files in accordance with the established AML/CFT risk frequency for each user;

- Risk Level Updates: Update a user's risk level during each review or following a triggering event, such as a material change in the business relationship (e.g., a user becoming a Politically Exposed Person (PEP)), adverse media, third-party alerts, or as needed to process alerts or enhanced reviews;

- High-Risk Transaction Review: Determine appropriate review for high-risk transactions in terms of AML/CFT compliance procedures.

Constant vigilance during a relationship may lead to a change in risk level and the implementation of enhanced monitoring when transactions are flagged as red or atypical.

Furthermore, WhiteBIT Kazakhstan reserves the right to prohibit both incoming and outgoing suspicious or authorized transactions (or transactions executed from/to/by authorized entities). This includes freezing funds involved in such transactions and suspending and/or terminating access to WhiteBIT Kazakhstan products/services.

Alerts, abnormal activity, unusual or questionable behavior

A transaction that may raise red flags, abnormal activity, or unusual or questionable behavior often deviates from the User's established legitimate business or personal activity, or from the usual transactions typical for that particular User profile. Therefore, a key element of identification is having sufficient knowledge of the User's business to recognize any unusual or irregular transaction or series of transactions.

WhiteBIT Kazakhstan collects evidence of the purpose of the funds and the identity of the beneficiary from Users. Additionally, information regarding the origin of the funds and the purpose of the transaction is requested.

While a document (e.g., a bank statement, a cash declaration) may be provided to help establish the origin of the funds (e.g., inheritance, real estate sale), this alone may not be sufficient to substantiate the source of the funds. Declarations or confirmations provided by the User within the context of a business relationship cannot be considered definitively sufficient. If WhiteBIT Kazakhstan encounters resistance from a User who refuses to disclose relevant evidence, citing commercial or professional confidentiality, WhiteBIT Kazakhstan considers this grounds for questioning. In this scenario, doubts persist, which may lead to termination of the business relationship.

In the area of ​​AML/CFT, international laws and regulations require us to adhere to all the aforementioned compliance procedures, including collecting all necessary additional documents and information from Users, as part of our AML/CFT policy.

AML/CFT Compliance Officer

The AML/CFT Compliance Officer, duly authorized by WhiteBIT Kazakhstan, is responsible for overseeing and ensuring the effective implementation of anti-money laundering/combatting the financing of terrorism (AML/CFT) measures. This includes reporting any violations of AML/CFT protocols and managing the collection and submission of suspicious activity reports (SARs).

The AML/CFT Compliance Officer's responsibilities encompass comprehensive oversight of all aspects related to WhiteBIT Kazakhstan's AML/CFT efforts. These responsibilities include, but are not limited to:

- Establishing and regularly updating internal policies and procedures in accordance with relevant laws and regulations. This includes managing the completion, review, submission, and retention of mandatory reports and records;

- Collecting user identification information, verifying the data provided, and implementing a records management system for proper document retention and retrieval;

- Collecting and analyzing information related to unusual transactions or suspected criminal activity, money laundering, or terrorist financing;

- Conducting investigations of any unusual or criminal activity identified;

- Promptly reporting money laundering or terrorist financing to the relevant authorities and providing the necessary information in accordance with regulations;

- Periodically providing written representations to the management board confirming compliance with legal requirements;

- Organizing training programs for specialists to ensure awareness and compliance;

- Performing other duties and obligations related to compliance requirements;

- Regularly updating the risk assessment to reflect changing circumstances and changes in regulations;

The Compliance Officer has the right and authority to interact with competent law enforcement and regulatory authorities involved in the prevention of money laundering, terrorist financing and other illegal activities.

AML/CFT training

WhiteBIT Kazakhstan specialists undergo comprehensive AML/CTF training. This training is conducted at least once every twelve (12) months to ensure specialists are well-informed and comply with all relevant laws and regulations. Additional training is conducted as needed, for example, in the event of the adoption of new laws or regulations or in accordance with legal requirements.

The AML/CTF training program is regularly updated to align with the latest laws and regulations, ensuring it remains relevant and in line with current standards.

Documentation storage

WhiteBIT Kazakhstan will retain the following records for six (6) consecutive years after termination of the relationship with the User:

- Copies or links to evidence obtained regarding the User's identity and details of the User's trading activity for six (6) years from the date of the relevant transaction.

- All User communications, including emails or recorded calls.

In addition, WhiteBIT Kazakhstan will retain internal records for six (6) years, including:

- Records documenting all AML/CFT training sessions conducted.

- Details describing actions taken in relation to both internal and external reports.

WhiteBIT Kazakhstan will ensure strict compliance with these requirements, ensuring that documents are available upon request.

Final Provisions

This AML/CFT Policy is effective upon publication on our website and remains in effect except for any future changes to its provisions, which will be effective immediately upon publication on the website.

We may update and/or change the terms of this AML/CFT Policy, and you are responsible for monitoring all relevant updated documents.

If you do not agree with this AML/CFT Policy, you should refrain from using our website, existing applications, and/or Services, or opening an account. This AML/CFT Policy forms part of our User Agreement.

If you have any questions about this AML/CFT Policy, please contact us at aml@whitebit.kz