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Anti-Money Laundering Policy (AML Policy)

Money laundering is concealing illegal funds by turning them into cash, or into investments, which seem to be legitimate.

As Bitci, we attach great importance to providing the best customer service, and account security is also very important for us. In order to prevent any form of money laundering, we strictly apply our AML (Know-Your-Customer) Policy. The Anti-Money Laundering Policy (shall be referred to as “AML Policy” hereinafter) summarized procedures and mechanisms determined by Bitci to prevent money laundering.

The aim of the AML policy is to minimize risks by assessing customers, transactions, and services of Bitci Teknoloji ve Bilişim A.Ş based on a risk-based approach; to raise awareness of the employees on prevention of crime and financing of terrorism, and informing the customers that the Company carries out its operations in compliance with the applicable legislation, particularly with Law No 5549 on the Prevention of Laundering Proceeds of Crime, and Law No. 6415 on Prevention of Financing of Terrorism.

For the purpose of this AML Policy, customers who are subject to this policy to avoid any damage to Company operations, refer to natural persons who are registered with the platform accessed at www.bitci.com (“Platform”), uses the services on the Platform and accepts the provisions of the AML Policy, by accessing the Platform and using the services.

Bitci AML Policy is developed in compliance with the international legal norms and standards, and implemented in compliance with the applicable legislation, and the Company has taken many measures in order to implement and supervise the implementation of the AML policy, including authentication of all the customers to a reasonable extent, adopting a risk-based approach to monitor customer transactions, reporting suspicious transactions of customers to competent institutions and authorities according to applicable legislation, and recording transactions.

1. Therefore, Bitci adopts below policies:

• Bitci refrains from dealing with criminals and/or terrorists
• Bitci refrains from processing transactions arising from criminal and/or terrorism activities,
• Bitci refrains from facilitating any transaction related to criminal and/or terrorism activities

2. Risk assessment

Bitci adopts a risk-based approach to prevent money laundering and financing of terrorism in compliance with national and international requirements. Therefore, measures to prevent money laundering and financing of terrorism are proportionate to the risks that are identified and allow dedicating resources in the most effective way. Resources are used based on priority, and greatest importance is given to the highest risks.

Since Bitci adopts a risk-based approach in monitoring financial activities of the customers, it makes a risk analysis using below methods to prevent money laundering and financing of terrorism, and may start tracking the customers according to the results of the risk analysis.

Customers and transactions that are in the high-risk group are listed below:
• When the total amount of a single or multiple and connected cryptocurrency trading transaction is TL 100,000.00 or more;
• When the total amount of a single or multiple and connected cryptocurrency swap transaction is TL 100,000.00 or more;
• When there is any situation requiring reporting suspicious transaction under the applicable legislation, notwithstanding the relevant amount;
• When there is any suspicion of the accuracy and sufficiency of identity details obtained beforehand, notwithstanding the relevant amount;
• When complicated transactions are made, which have the potential to conceal third party beneficiaries
• When the origin of the money cannot be verified easily
• When there is any unusual transaction, which has no economic or evident legitimate purpose

3. Monitoring Transactions

Monitoring customer transactions and analyzing the monitoring data is an important tool for risk assessment and detection of suspicious transactions. If there is a suspicion of money laundering, Bitci shall be entitled to monitor all transactions (high-risk customers and transactions, complicated and unusual transactions, transactions with high risk countries, customer information and documents, written and mandatory information that must be kept in relation to the purchase and sale of cryptocurrency, whether a transaction carried out by a customer is in compliance with the relevant transaction information) and to

• Reporting suspicious transactions to relevant law enforcement units;
• Requesting additional information and documents from the customer;
• Suspending or terminating the customer account.

The above list is not exhaustive, and the AML Policy Compliance Officer specifies that customers will monitor their transactions on a daily basis and will report on them and evaluate whether they can be considered as suspicious or not.

4. Know-Your-Customer Policy

You may access more detailed information on the Know-Your-Customer Policy at Protection of Personal Data

5. Authentication Procedure

Bitci will develop its procedures to determine compliance with anti-money laundering standards and KYC policy.

• Bitci customers complete an authentication procedure (they have to provide an ID approved by public authorities: passport of ID card). Bitci reserves its right to collect ID details of its customers for implementation of the AML Policy. This information is processed and retained securely in compliance with Bitci Privacy Policy.
• Bitci may ask the customer to provide a second identification document (a bank receipt or an electricity/water bill, which was issued in the last three months and contains full name and actual address of the customer)
• Bitci reserves its rights to request additional information on customers who are defined as dangerous or suspicious after verifying the information and documents provided by the customer.
• If the identity details of the customer have been changed, or his/her activities are found suspicious, Bitci reserves its right to request up-to-date documents from the customer even if his/her identity has been verified in the past.

6. Reporting

In case of suspicion of money laundering and financing of terrorism in relation to services provided by Bitci, transactions determined to be suspicious after due examination are reported to the Financial Crimes Investigation Board, regardless of the amount of such transactions. Natural persons making the suspicious transaction, and their legal representatives, and managers and employees failing to comply with the obligation to report a suspicious transaction shall be held liable against legal, administrative, and criminal sanctions.

7. AML Officer

AML Officer is a Bitci employee who is responsible for ensuring compliance with the AML Policy. AML Officer is responsible for

• Collecting ID details of the customers
• Developing and updating internal policies and procedures for generating, reviewing, submitting, and retaining all reports required under applicable laws and regulations,
• Monitoring and analyzing important deviations arising from unusual activities of the customers
• Implementing a record management system for recording and retrieving documents, files, forms, and daily session log-ins and log-outs.
• Regularly updating risk assessments.

8. Training, Updating and Internal Audit

Bitci fulfills its obligations related to training with its employee policy and procedures developed in compliance with the applicable legislation. Employees are given training in many areas, particularly in AML Policy to ensure that their knowledge remains fresh.

Bitci carries out periodical audits to ensure compliance of its operations with the Law on Prevention of Money Laundering and Financing of Terrorism, applicable regulations and communiqués, Company policies and procedures.

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