For the purpose of preventing the risk related to legalization of funds from criminal activities and financing of terrorism, the company Digital Ocean s.r.o. applies the system of AML rules and measures.

The process of legitimizing profits from unlawful activities, commonly known as "money laundering," involves a customer using the services of Digital Ocean s.r.o. to obscure the illicit origins of their assets or to hinder their traceability. Similar regulations to those enforced by Digital Ocean s.r.o. are obligatory for comparable businesses in the Czech Republic and other nations, given that money laundering and terrorism financing are frequently conducted on an international scale.

Digital Ocean s.r.o. routinely checks whether customers are subject to international sanctions and follows additional procedures detailed below.

For the purposes of this document, the AML act means Act No. 253/2008 Coll. on some measures against legalization of revenues from criminal activities and terrorism financing.

Digital Ocean s.r.o. has the assigned Compliance officer who is responsible for implementation of AML policy, including but not limited to, of the below listed activities.

The company adheres to the following AML protocols:
1. Client Identity Verification: Prior to establishing any business relationship, we verify the client's identity thoroughly.
2. Risk-Based Client Due Diligence: Implementing and upholding a system of client due diligence tailored to the perceived risk level, with heightened scrutiny for clients deemed to present elevated risks.
3. Transaction Monitoring: Continuously monitoring of transactions based on meticulous risk assessments.
4. Reporting Suspicious Activity: Vigilantly reporting any suspicious activities internally, and, when mandated by relevant laws and regulations, promptly notifying the appropriate authorities.
5. Regular AML Training: Regularly conducting comprehensive AML training sessions for the team members to ensure they remain abreast of the latest protocols and practices.

To ensure the integrity of our services and comply with legal requirements, Digital Ocean s.r.o. must verify the identity of every customer before granting access to our services. This process is essential in preventing terrorism financing and money laundering. By law, financial institutions are required to obtain, verify, and record identifying information from anyone seeking to trade with us. Therefore, we will need your name, address, date of birth, and other pertinent details about you, your organization, or related individuals before we can proceed with any transactions.

If a customer is assessed by Digital Ocean s.r.o as having a higher risk profile, a more thorough investigation will be conducted. This may involve requesting additional information and a longer verification period.

Digital Ocean s.r.o. retains the right to verify a customer's identity continually, especially when there are changes in identification details or if the customer's activities appear suspicious or out of the ordinary. We may also request updated documents from the customer, regardless of previous verifications.

All collected identification information will be handled in strict compliance with Digital Ocean s.r.o.'s Privacy Policy and relevant regulations, ensuring it is securely collected, stored, and shared.

The Users are obloged to provide:
- Full name.
- State-assigned identification number (supported by documents such as a photocopy of a national ID, international passport, or other ID documents).
- Date of birth.
- Nationality.
- Telephone number.
- Email.
- Address (supported by documents such as a bank statement and utility bill as proof of address).
- Other information or documents requested by the Company (photo of the Client, documents confirming the source of funds, etc.).

If we will need more thorough check, Users will be requested to provide additional identity, address, and financial status verification documents for identity verification as per this AML-KYC Policy, including:

For Individuals:
- Identity Document: A color copy of the passport, a color copy of an identity document recognized by the legislation of the user's resident country, or a valid driving license. The Company shall accept only driving licenses issued in the European Union Member States. A driving license is acceptable if it contains the name of the Customer, the facial image of the Customer, the signature or an image of the signature of the Customer, and the residential address of the Customer. The document must not have been used as the basis for the identification of the Customer as a natural person in accordance with paragraph 3 of this Section of the Policy. The Company shall accept only a photo of the original document.
- Government-Issued Document: A document such as a tax statement that clearly shows the individual's residential address.
- Bank Statement: Dated within the last 3 months.
- Utility Bill: Dated within the last 3 months.

For Legal Entities:
- Corporate Documentation: A copy of the extract from the protocol of the general meeting of participants/shareholders, certificate of directors and secretary, minutes of the first meeting of directors, register of directors, or another document verifying the appointment of directors, or an equivalent document confirming the registration of corporate acts and amendments, and the authority of the company head.
- Head's Identity Document: A passport copy of the company head (passport copies of all individuals who, directly or indirectly, own more than 25 percent of the company's share capital may also be required).
- Location Confirmation: A document verifying the legal entity’s location or actual business address (such as a utility bill dated within the last 3 months or a copy of the office rental agreement).
- Certificate of Incorporation: A copy of the certificate of incorporation.
- Memorandum and Articles of Association: A copy of the memorandum and articles of association or an equivalent document, duly registered with the appropriate authority.
- Shareholders Certificate: A certificate of shareholders or register of members.
- Bank Reference Letter: A reference letter from the bank confirming the opening of a current account, or a copy of the bank contract for the account opening.
- Certificate of Good Standing: A copy of the certificate of good standing.

Digital Ocean s.r.o.  adheres to a risk-based approach to fulfill its obligations regarding Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF). This approach allows for the identification, evaluation, and comprehension of the money laundering and terrorist financing risks faced by Digital Ocean s.r.o., facilitating the implementation of suitable mitigation measures in accordance with the level of risk.

1. Customer-Related Risk

Suspect Indicators: Discrepancies in provided identification documents, fictitious identities, stolen identities, counterfeit documentation, usage of post box addresses, prior records of financial crime, connections to terrorism, individuals with warrants, absence of valid contact information, discrepancies in provided legal entity documents, etc.

Politically Exposed Persons (PEPs): Individuals occupying prominent public positions such as heads of state or government, ministers, parliament members, political party governing body members, supreme court members, ambassadors, high-ranking military officials, state-owned enterprise directors, international organization directors, etc.

2. Country-Related Risk

The Anti-Money Laundering Directive imposes stricter due diligence requirements for business relationships or transactions involving high-risk third countries. This entails gathering additional information on the customer and beneficial owner, the origin of funds and assets, the purpose of the transaction, and obtaining senior management approval to initiate or maintain the relationship.

Low-Risk Clients:
- Clients residing in a member state of the European Union, a member state of the European Free Trade Association (EFTA), or a party to the European Economic Area (EEA) Agreement.
- Clients residing in a third country recognized by credible sources as having a low prevalence of corruption or other criminal activities.
- Clients residing in a third country where robust Anti-Money Laundering/Counter Terrorist Financing (AML/CFT) regulations are effectively enforced.

High-Risk Clients:
- Clients whose identity information's authenticity, validity, and/or integrity are doubted by the company.
- Clients originating from or situated in a high-risk third country.
- Clients classified as Politically Exposed Persons (PEPs).
- Transactions labeled as unusual.
- Clients displaying suspicious behavior prompting concerns of misconduct.

If you have any questions or concerns regarding the current AML-KYC policy, don't hesitate to reach out to us. You can also contact us via email at info@easyswapper.io. We're here to assist you.

Last revised: March 18, 2025