AML/KYC Policy

Countering Money Laundering and the Financing of Criminal Activity

Antarctic Wallet LLC

Antarctic Wallet LLC (the “Company”) is committed to providing services lawfully and responsibly. The Company takes measures to prevent the Antarctic Wallet platform from being used for money laundering, terrorist or extremist financing, the financing of organized criminal groups or criminal organizations, the financing of the proliferation of weapons of mass destruction, or other unlawful activities.

This Policy outlines the general principles of the Company’s approach to preventing money laundering and the financing of criminal activity, and to customer identification and verification (AML/KYC). These principles are applied in light of the relevant requirements of Kyrgyz Republic law and the nature of the services provided by the Company.

The Company applies a risk‑based approach. The extent of due diligence takes into account information about the customer, the nature of the transactions, the services used and geographical factors. Checks may be conducted when a business relationship is established and throughout the relationship. Enhanced due diligence measures apply where the risk is higher.

A risk assessment may change as new information about a customer or their transactions becomes available. A low‑risk assessment does not waive mandatory identification requirements or rule out further checks. A higher‑risk assessment calls for proportionate controls and does not, by itself, establish that the law has been breached.

Customer due diligence includes identifying and verifying the customer, understanding the purpose and intended nature of the business relationship and, where applicable, identifying the beneficial owner, verifying any representative and checking their authority. The Company may request information and documents needed for these checks, including evidence of the source of funds and, where warranted, the source of wealth.

Customers must provide accurate, complete and up‑to‑date information, promptly notify the Company of changes and respond to its reasonable requests. Completion of initial verification does not preclude requests for further information or renewed checks.

The Company does not permit the platform to be used to carry out or conceal unlawful transactions, maintain anonymous or fictitious accounts, provide information known to be false, or conceal the person for whose benefit a transaction is conducted. Attempts to circumvent identification requirements, sanctions restrictions or other mandatory controls are not permitted.

Customers must comply with restrictions on activities and transactions imposed by law and the terms of service. When using services under the Terms of Use (Public Offer), a customer acts in their own name, for their own benefit and on their own account, and uses the services for personal, non‑business purposes. A customer’s willingness to accept risk does not replace mandatory checks or provide a basis for carrying out a prohibited transaction.

When providing services to organizations under separate agreements, the Company obtains information about their registration, business activities, ownership structure, management and beneficial owners. Due diligence also covers the authority of persons acting on an organization’s behalf. Where necessary, documents are requested to establish the commercial rationale for the proposed transactions and the source of the funds involved.

When selecting business partners and service providers, the Company considers the nature of their activities, their legal authority to provide the relevant services and the risks associated with the relationship. The extent of due diligence depends on the counterparty’s role. Engaging providers of identification, analytics or other services does not relieve the Company of its own legal obligations.

The Company screens customers and other persons subject to screening against sanctions and other lists where required by law, and takes account of restrictions set out in the terms of service. Where relevant circumstances are identified, the measures prescribed by law, including targeted financial sanctions, apply.

Additional due diligence measures apply to politically exposed persons, their family members and close associates. Such status does not, by itself, imply involvement in unlawful activity.

The Company analyzes transactions to identify unusual or suspicious activity and inconsistencies with the information it holds about a customer. Blockchain address and transaction analytics tools are used for transactions involving virtual assets. Where required by law, the Company obtains, retains and transmits information about the originator and beneficiary of a transfer.

Automated risk assessments are considered alongside other available information. They do not, on their own, confirm whether assets have a lawful or unlawful origin, and do not guarantee that a transaction will be accepted by the Company or any third party.

When reviewing a transaction, the Company may request information about the originator and beneficiary, the purpose of the transaction, the relationship between its participants and the ownership of the accounts, payment instruments or wallet addresses used. Transactions involving personal wallets that are not serviced by virtual asset service providers are subject to the identification requirements for wallet holders prescribed by law.

Where grounds exist under applicable law or the terms of service, the Company may request further documents and explanations, decline to establish or continue a business relationship or to carry out a transaction, suspend a transaction, or restrict access to particular platform functions. Funds and virtual assets are frozen only in the circumstances and in accordance with the procedures prescribed by law.

The duration of a review is determined by the Company’s internal documents, taking into account legal requirements, the nature of the review and the need to obtain further information, including from the customer and third parties. The timing and procedures for imposing and lifting restrictions are governed by law, requirements and decisions of competent authorities and the terms of service. Measures imposed pursuant to a requirement or decision of a competent authority remain in effect until lifted in accordance with the applicable procedure. This Policy does not establish a single deadline for the completion of all reviews.

A request for further information or renewed verification does not, by itself, mean that the Company considers a customer to be involved in unlawful activity. Such measures may be necessary to clarify information, confirm the nature of transactions or comply with legal requirements.

Customers may provide explanations and supporting information, report errors or changes in information previously supplied, and contact the official support service about a review or any restrictions imposed. Inquiries are handled in accordance with the terms of service and legal restrictions on the disclosure of information.

Additional materials are taken into account when assessing the circumstances and whether services may continue to be provided. Providing such materials does not automatically result in restrictions being lifted. Once the grounds for restrictions cease to exist, the restrictions are lifted in accordance with the procedures prescribed by law and the terms of service, taking into account the requirements and decisions of competent authorities.

The terms of service govern the procedures and time limits for submitting and considering complaints and for resolving disputes. The period for considering a complaint is not a deadline for completing an AML/KYC review or lifting restrictions.

The Company submits suspicious transaction reports and other information required by law to the financial intelligence unit, and cooperates with other competent authorities acting within their powers. The Company observes legal prohibitions on disclosure, including the prohibition on notifying a customer that a suspicious transaction report has been submitted.

Personal data is processed on lawful grounds, taking into account the purposes of due diligence and confidentiality requirements. Information may be shared with service providers engaged by the Company and other parties involved in providing services to the extent necessary and where a lawful basis exists. Further information is set out in the Privacy Policy. Closing an account or withdrawing consent does not end the retention or processing of information to the extent required by law.

The Company’s AML/KYC approach is based on defined responsibilities, documented decisions and confidentiality. Its internal rules provide for staff training, risk assessments and reviews of compliance with control procedures. Specific powers, decision‑making procedures and operational instructions are set out in internal documents.

The approach is developed in light of changes in law, the nature of products and services, delivery channels, geographical reach and identified risks. Expanding the platform’s functionality does not remove the need to comply with applicable AML/KYC requirements.

This Policy is provided for information and does not replace the Company’s internal rules and procedures. It does not amend the Company’s Terms of Use (Public Offer) or other agreements with customers, create an independent entitlement to services, or guarantee that transactions will be carried out or restrictions will not be imposed. The terms on which services are provided are governed by applicable law and the relevant agreement.

The Company reviews this public Policy in light of changes in law and the nature of its business. The current version is published on the Antarctic Wallet website.

Questions about this Policy may be sent to legal@antarcticwallet.com or submitted through the official support service listed on the website. Identity documents and biometric materials should be provided only through the designated verification interface, following the platform’s instructions. Do not send such materials by email or through the support chat.