Anti-Money Laundering (AML) Policy

1. Introduction

FFOLLOWME OÜ ("INFRA CORE PLATFORM", "we", "us", or "our") is committed to the highest standards of Anti-Money Laundering (AML) compliance and Counter-Terrorist Financing (CTF). This policy outlines our approach to preventing the use of our platform for money laundering, terrorist financing, and other financial crimes.

As a regulated financial institution operating in Estonia and the European Union, we comply with all applicable AML/CTF laws and regulations, including but not limited to:

• Estonian Money Laundering and Terrorist Financing Prevention Act
• EU 5th and 6th Anti-Money Laundering Directives (5AMLD/6AMLD)
• FATF Recommendations
• EU Funds Transfer Regulation

2. Risk-Based Approach

We employ a risk-based approach to AML/CTF compliance, which includes:

3. Customer Due Diligence (CDD)

We implement robust Customer Due Diligence procedures that include:

Standard Due Diligence

• Verification of customer identity using reliable, independent sources
• Identification and verification of beneficial owners
• Understanding the nature and purpose of the business relationship
• Ongoing monitoring of customer transactions and activities

Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to high-risk customers, including:

• Politically Exposed Persons (PEPs) and their family members/close associates
• Customers from high-risk jurisdictions
• Customers with complex ownership structures
• High-value or unusual transactions
• Correspondent banking relationships

4. Know Your Customer (KYC)

Our KYC procedures are designed to establish and verify the identity of our customers:

5. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect and report suspicious activities:

• Real-time transaction screening against sanctions lists
• Pattern-based detection of unusual transaction behavior
• Machine learning algorithms for anomaly detection
• Regular review of customer transaction history
• Threshold-based alerts for high-value transactions

6. Sanctions Compliance

We screen all customers and transactions against relevant sanctions lists, including:

• EU Consolidated Sanctions List
• UN Security Council Sanctions List
• OFAC SDN List (US Office of Foreign Assets Control)
• UK HM Treasury Sanctions List
• Other relevant national and international sanctions lists

7. Suspicious Activity Reporting

We are committed to reporting suspicious transactions to the relevant authorities:

8. Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

• Customer identification and verification documents: minimum 5 years after relationship ends
• Transaction records: minimum 5 years from the date of the transaction
• Internal reports and investigations: minimum 5 years
• Training records: maintained for the duration of employment plus 5 years

9. Training and Awareness

We provide comprehensive AML/CTF training to all employees:

• Initial AML training for all new employees
• Annual refresher training for all staff
• Role-specific training for compliance and customer-facing staff
• Updates on regulatory changes and emerging risks
• Documentation and testing to ensure understanding

10. Governance and Oversight

Our AML/CTF compliance framework includes:

11. Cryptocurrency-Specific Measures

Given our involvement in cryptocurrency services, we implement additional measures:

• Blockchain analytics tools for transaction tracing
• Wallet screening against known illicit addresses
• Travel Rule compliance for virtual asset transfers
• Enhanced monitoring for privacy coins and mixing services
• Regular assessment of cryptocurrency-specific risks

12. Contact Information

For questions about our AML/CTF policies or to report suspicious activities: