Anti Money Laundering

Compliance and Supervisory Procedures

Effective date: April 1, 2022

1. Firm Policy

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the following regulation (hereinafter AML Regulation):

• Act No. 253/2008 Coll. on Selected Measures against Legitimisation of Proceeds of Crime and Financing of Terrorism
• Act No. 69/2006 Coll. on the Implementation of International Sanctions
• Act No. 254/2004 Coll. on Restriction of Cash Payments
• Regulation (EU) No 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006
• Regulation (EC) No 1889/2005 of the European Parliament and of the Council on controls of cash entering or leaving the Community

2. AML Compliance Person Designation and Duties

The firm has designated Tomas Hnilicka, statutory body of IVBF, s.r.o., as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. The AML Compliance Person has a working knowledge of the respective regulations and is qualified by experience, knowledge, and training.

The duties of the AML Compliance Person include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees, maintaining all required AML records, and ensuring Suspicious Activity Reports (SARs) are filed with the Financial Analytical Bureau (FAB) when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.

The firm will provide FAB with the AML Compliance Person’s name, title, mailing address, email address, and telephone number. FAB will be promptly notified of any changes and the information will be reviewed and updated within 17 business days after the end of each calendar year.

3. Checking the Office of Foreign Assets Control Listings (OFAC)

Before opening an account, and on an ongoing basis, the AML Compliance Person will check to ensure that a customer does not appear on the SDN list or is not engaging in transactions prohibited by OFAC-administered sanctions and embargoes.

The SDN list and sanctions are updated frequently. We will consult them regularly, subscribe to updates, and may use software tools such as OFAC’s Sanctions List Search for speed and accuracy. Existing accounts will be reviewed against updated lists, and all reviews will be documented.

If a customer appears on the SDN list or engages in prohibited transactions, we will reject the transaction and/or block assets, file the required OFAC forms within 10 days, and call the OFAC Hotline at (800) 540-6322 immediately.

Our review covers customer accounts, transactions involving customers (including wires), and transactions involving physical securities or application-based investments.

4. Customer Identification Program (CIP)

In addition to AML Regulation requirements, we maintain a written CIP. This program includes collecting minimum identification information, using risk-based measures to verify identity, recording the information and verification results, notifying customers that identification is required, and comparing against government-provided terrorist lists when applicable.

a. Required Customer Information

Before opening an account, the AML Compliance Person will collect:

1. Name
2. Date of birth (for individuals)
3. Address – residential, business, APO/FPO, or next-of-kin (individuals); principal place of business or other location (entities)
4. Identification number – taxpayer ID (US persons) or equivalent (non-US persons)

If a foreign entity has no identification number, alternative government-issued documentation will be requested.

b. Customers Who Refuse to Provide Information

If a potential or existing customer refuses or provides misleading information, the firm will not open an account and may close an existing account. The AML Compliance Person will determine whether to report to FAB.

c. Verifying Information

We will verify identities using documentary methods (e.g., unexpired government-issued ID, business license, incorporation documents) and non-documentary methods (e.g., public database checks, financial statements, references).

Non-documentary methods are used if documents are unavailable, unfamiliar, there is no face-to-face contact, or other risk factors apply.

d. Lack of Verification

If we cannot reasonably verify a customer’s identity, we will:

1. Not open the account
2. Restrict transactions until verification
3. Close the account if unresolved
4. Consider filing a FAB notice

e. Recordkeeping

We will keep all identifying information, verification records, and resolutions of discrepancies for 5 years after account closure (or record creation for verification).

f. Comparison with Government-Provided Lists of Terrorists

If a government list is issued for CIP purposes, we will check all accounts promptly and follow all directives. Even as a non-US entity, IVBF, s.r.o. complies with OFAC rules.

5. Monitoring Accounts for Suspicious Activity

We monitor accounts for unusual size, volume, patterns, or types of transactions based on customer risk profiles. Urgent cases such as terrorist financing or ongoing money laundering will be reported immediately to law enforcement and OFAC, followed by a FAB notice.

6. AML Recordkeeping

The AML Compliance Person ensures all AML records are properly maintained and FAB notices filed as required. FAB notices and supporting documentation will be kept for at least 5 years.

Signed: Tomas Hnilicka
Title: Statutory Body
Date: April 12, 2022

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