Border X Digital

Border X Digital is a trading name of STANDARD 13 Sp. z o.o., a Virtual Asset Service Provider (VASP) registered in Poland (KRS: 0001136700, NIP: 5833523090), licensed by the Polish Financial Supervision Authority (KNF) under License No. RDWW-1827.

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines our commitment to preventing money laundering, terrorist financing, fraud and other financial crimes in accordance with the Polish AML Act of 1 March 2018 and applicable EU directives.

1. Compliance Responsibilities

We implement effective internal controls to detect, mitigate and report suspicious activities. Our designated Compliance Officer oversees the execution of this policy, including monitoring, staff training, reporting and liaison with regulatory authorities such as the General Inspector of Financial Information (GIIF).

2. Customer Verification

Prior to accessing our services, all customers must undergo a Know Your Customer (KYC) process. We use the regulated third-party provider, KCYaid, to carry out secure, automated verification, which includes:

• Full name, date of birth, nationality

• Government-issued photo ID (passport, ID card, or driver's license)

• Proof of residential address (e.g. utility bill or bank statement)

• Facial recognition (liveness check) for identity match

We reserve the right to request additional documentation or re-verification, especially if:

• Customer information changes

• Suspicious activity is detected

• Risk level increases

All customer data is collected and processed in compliance with our Privacy Policy and applicable data protection laws.

3. Risk Assessment

We apply a risk-based approach to all customers and transactions. Each customer is assessed using an internal risk scoring system, which considers:

• Type and nature of customer (e.g., individual, corporate, PEP)

• Geographic risk (e.g., high-risk or sanctioned countries)

• Transaction behaviour and volume

• Adverse media and sanctions screening

Customers are classified as low, standard or high risk. Those identified as high risk undergo Enhanced Due Diligence (EDD), which may include:

• Verification of source of funds

• Detailed beneficial ownership checks

• Senior management approval prior to onboarding

4. Ongoing Monitoring

Customer activity is subject to continuous monitoring using both automated tools and manual reviews. We detect and assess:

• Unusual transaction patterns

• Large, rapid or unexpected movements of funds

• Involvement in high-risk sectors or jurisdictions

• New information from watchlists or sanctions lists

We conduct daily screening for sanctions, PEPs and adverse media using automated systems.

5. Reporting Obligations

Any suspected activity that may involve money laundering or terrorist financing is reported to the General Inspector of Financial Information (GIIF). Such reports are:

• Filed confidentially by the Compliance Officer

• Not disclosed to the customer under any circumstance

• Retained as part of our audit trail for regulatory access

6. Record-Keeping

We retain customer identification data, risk assessments, transaction records and internal decisions for a minimum of 5 years after the end of the customer relationship or completion of a transaction, in accordance with Polish AML regulations.

7. Staff Training

All employees involved in customer onboarding, transaction handling, or compliance are regularly trained on:

• AML/CTF obligations

• Red flags and suspicious behaviour indicators

• Internal procedures for escalation and reporting

• Training is refreshed annually or in response to major regulatory changes.

8. Policy Review

This AML/CTF Policy is reviewed and updated at least once per year or following any significant change in applicable laws, regulations or business operations. Updates are reviewed by the Compliance Officer and approved by senior management.

For any questions regarding this policy, please contact our Compliance Team at:

compliance@borderxdigital.eu | Tadeusza Jasińskiego 65/40, 80-175 Gdańsk, Poland