1. Introduction

The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as the “AML/KYC Policy”) is intended to prevent and reduce the possible risks of Aztec Gold being involved in any illegal activity.

2. Purpose of internal regulation

The Aztec Gold service adheres to practices and measures in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that Aztec Gold takes seriously any attempts to use its service for illegal purposes.

3. Caution

The Aztec Gold service warns users against attempting to use the Aztec Gold service for money laundering, terrorist financing, fraud of any kind, as well as against using the service to purchase prohibited goods and services.

The Aztec Gold service, its administration, employees and domain owners are not responsible for the unlawful use of the service by third parties, the actions of attackers and possible damage associated with the use of the Aztec Gold service.

4. Requirements

To prevent illegal transactions, the Aztec Gold service establishes certain requirements for all Applications created by the User:

4.1. The sender and recipient of the Payment under the Application must be the same person. Using the Services, transfers in favor of third parties are strictly prohibited.

4.2. All contact information entered by the User in the Application, as well as other personal data transmitted by the User to the Service, must be current and completely reliable.

4.3. It is strictly prohibited for the User to create Applications using anonymous proxy servers, VPN, Tor or any other anonymous connections to the Internet.

5. Verification Procedures

One of the international standards for preventing illegal activities is customer due diligence (hereinafter referred to as Verification). To this end, Aztec Gold implements its own verification procedures to strict anti-money laundering and Know Your Customer procedures.

5.1. The Aztec Gold Service may require that the User provide the Aztec Gold Service with reliable, independent source documents, data or information in order to undergo verification and confirm the sources of origin of funds. What is required may include:

* A photograph with a passport, in expanded form, where the photograph and full name are clearly visible;

* Scan or photograph of the passport (first, second pages and page with registration in good quality);

* Confirmation of the sources of origin of funds (photos, screenshots, statements);

* A video in which the person who sent the funds, holding an expanded passport in his hands (where the photograph and full name are clearly visible), says that he created an application ID (application number) at the Aztec Gold exchange office, the funds sent are my personal and I I bear full legal responsibility for this cryptocurrency, it is also necessary to mention in the video the source of origin of the funds;

* Record a video taken from the platform from where the funds were sent, in the video we should see the hash, address of the sender and recipient, the amount with the ticker and the date of the transaction. The duration of the video must be at least 10 seconds.

5.2. In case of blocking, due to high risk or official investigation, funds will be withheld until verification is completed or the investigation is completed. For such purposes, the Aztec Gold Service reserves the right to collect User identification information for the purpose of complying with the AML/KYC Policy.;

5.3. Aztec Gold Service will take steps to verify the authenticity of documents and information provided by Users. All legal methods will be used to double check identification information, and Aztec Gold Service reserves the right to investigate certain Users whose identities have been determined to be dangerous or suspicious.

5.4. The Aztec Gold service reserves the right to verify the User's identity on an ongoing basis, especially when his identification information has been changed or his activity seems suspicious (unusual for a particular User). In addition, the Aztec Gold Service reserves the right to request current documents from Users, even if they have been authenticated in the past.

5.5. User identification information will be collected, stored, shared and protected strictly in accordance with the Aztec Gold Service Privacy Policy and related regulations.

5.6. After confirming the user's identity, the Aztec Gold Service may refuse to provide services to the User in a situation where the services of the Aztec Gold Service are used to conduct illegal activities.

5.7. Users who intend to use payment cards for the purpose of consuming services must undergo card verification in accordance with the instructions available on the Aztec Gold website

5.8. The Aztec Gold Service has regulatory requirements to verify the source of funds or cryptocurrencies to ensure that the sources of funds that Users use to trade are legitimate.

6. Responsible Official

The AML Compliance Officer is the person duly authorized by Aztec Gold Service whose responsibility is to ensure the effective implementation and enforcement of the AML/KYC policy.

6.1. The duty of such official is to monitor all aspects of Aztec Gold's anti-money laundering activities, including money laundering and terrorist financing, including, but not limited to, the following methods: collection of user identification information;

* creating and updating internal policies and procedures for completing, reviewing, submitting and maintaining all reports and records required by applicable laws and regulations;

* monitoring transactions and investigating any significant deviations from normal activities;

* Implementation of a records management system for appropriate storage and retrieval of documents, files, forms and logs;

* regularly update the risk assessment;

* providing law enforcement with information required by applicable laws and regulations.

6.2. The AML Compliance Officer has the authority to interact with law enforcement agencies who are involved in the prevention of money laundering, terrorist financing and other illegal activities.

7. System functions

Aztec Gold performs a variety of compliance-related tasks, including data collection, filtering, record keeping, investigation management and reporting. System features include:

* daily screening of Users for the existence of recognized blacklists (e.g., OFAC), aggregation of transmissions across multiple data points, placement of users on watch lists and denial of service lists, opening cases for investigation where necessary, sending internal messages and filing mandatory reports, if applicable;

* management of affairs and documents.

8. Behavior analysis

The Aztec Gold service verifies Users not only by verifying their identity, but more importantly by analyzing their transaction behavior. Therefore, the Aztec Gold Service relies on data analysis as a tool for risk assessment and suspicion detection.

9. Risk assessments

Aztec Gold, in accordance with international requirements, applies risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, Aztec Gold ensures that measures to prevent or reduce money laundering and terrorist financing are commensurate with the identified risks.

10. Performing customer checks

If the administration of the Aztec Gold service has reasonable suspicions that the user is trying to use the services of the Service for money laundering or for the purpose of carrying out any other illegal transactions, the administration has the right:

* suspend the user's exchange operation;

* request identification documents from the User;

* request from the User any additional information and documents in case they carry out suspicious transactions;

* Ensure that suspicious transactions are reported to the appropriate law enforcement authorities through the AML Compliance Officer.

11. Privacy

The Aztec Gold service guarantees client confidentiality in accordance with the service's privacy policy.

11.1. Aztec Gold Service and its employees undertake to maintain confidentiality regarding any facts identified in connection with any questionable transaction. This obligation also applies to users of the Service and to third parties to whom transaction information has been communicated.

11.2. The obligation of confidentiality imposed on employees of the Aztec Gold Service remains in force after the termination of their employment or any other contractual relationship with the Aztec Gold Service, as well as upon the transfer of such employees to another workplace. Disclosure of such information to government, law enforcement agencies and other entities in cases specified by law does not constitute a violation of the obligation of confidentiality.

11.3. The obligation of confidentiality, provided that the use of information disclosed is limited to the prevention of the legitimization of proceeds of crime and terrorist financing, may not apply to disclosures between financial institutions forming a consolidated group that cooperates with the Aztec Gold Service.

12. Conclusion

In connection with the above, the Aztec Gold service does not bear any legal responsibility for its use for the purposes of money laundering, terrorist financing, or the purchase of prohibited goods and services, but undertakes to take all possible and available actions to prevent attempts to use the Aztec Gold Service for the purpose of laundering funds obtained by criminal means, financing terrorism, or purchasing prohibited goods and services.

By making an exchange, the User, in accordance with the clauses of the exchange rules applicable to Aztec Gold, agrees with all the terms of these policies and undertakes to comply with them.