AML/Compliance Policy for RAMPNOW Sp. z o.o.

Introduction
In compliance with the Polish Act on Counteracting Money Laundering and Terrorist Financing (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu), EU AML Directives, and best AML/CFT practices, RAMPNOW Sp. z o.o. has developed and implemented an AML/CFT Program, including Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures, aimed at reducing the risk of involvement in any illegal financial activities related to on-ramp and off-ramp services for cryptocurrencies. The company's management considers compliance with AML and CFT regulations to be of paramount importance and ensures that the requirements of this Program are met with the highest accuracy.

Occasional Transactions and Anti-Fraud Measures
Users may perform transactions up to the equivalent of PLN 15,000 per month without establishing business relationships with RAMPNOW Sp. z o.o., using the company's website or platform. In this case, relevant data is gathered, and appropriate anti-fraud controls are applied to such customers. If a user exceeds the limits or the company management deems it necessary to obtain additional information about the transactions, the user will be asked to undergo KYC verification.

Identity Verification (KYC)
To pass identity verification, users must provide personal information, residential address, and upload images of documents that support the provided information. Typically, a driver's license, passport, or national ID card will be provided for this purpose. A recent proof of residence must also be submitted to confirm the residential address.During the KYC verification procedure, RAMPNOW Sp. z o.o. is guided by a risk-based approach, so additional information regarding the nature of business relationships and the source of funds may be requested from users.The information provided by users is meticulously checked, both automatically and manually, to confirm the authenticity of the documents.

Ongoing Monitoring
RAMPNOW Sp. z o.o. will perform ongoing monitoring of customer relationships and transactions to ensure that the activities are consistent with the information obtained during the KYC process. If any suspicious activity is identified, the Compliance officer will investigate the case and, if necessary, report it to the Polish Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, GIIF).

AML/CFT
RAMPNOW Sp. z o.o.'s AML/CFT measures were developed to prevent money laundering activities and terrorist financing on the platform.Compliance officers maintain the policy by applying a risk-based approach while monitoring transactional activities on the platform.All transactions on the platform are automatically analyzed for suspicious patterns by the AML system. If a transaction or user's activity raises suspicion, the case is investigated by a properly trained Compliance officer. Compliance officers have the right to suspend transactions during the investigation.

Record Keeping
RAMPNOW Sp. z o.o. will maintain records of customer identification data, transaction records, and any other documents required by the Polish AML law for a period of five years after the termination of the business relationship or the completion of the transaction.

Training and Compliance
RAMPNOW Sp. z o.o. ensures that its employees receive adequate training in AML/CFT procedures and are aware of their responsibilities in this regard. The Compliance officer is responsible for overseeing the implementation of the AML/CFT Program and ensuring that it is updated as necessary to comply with changes in Polish AML law and international standards.

Privacy and Data Protection
Users' data is processed in accordance with RAMPNOW Sp. z o.o.'s Privacy Policy and Terms of Use, as well as in compliance with the Polish Personal Data Protection Act (Ustawa o ochronie danych osobowych) and the EU General Data Protection Regulation (GDPR).

Reporting and Cooperation with Authorities
RAMPNOW Sp. z o.o. is committed to cooperating with the Polish Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, GIIF) and other competent authorities in the fight against money laundering and terrorist financing. The company will promptly report any suspicious activities or transactions to the GIIF, in accordance with Polish AML law.

Sanctions
RAMPNOW Sp. z o.o. does not provide its services to natural persons or legal entities subject to sanctions, including, but not limited to, the sanction lists of the UN, EU, OFAC, or any other applicable sanction lists. The company uses appropriate screening tools and procedures to ensure that it does not engage in business relationships with sanctioned individuals or entities.

Updates and Amendments
RAMPNOW Sp. z o.o. reserves the right to update or amend this AML/Compliance Policy at any time to comply with changes in Polish AML law, international standards, or industry best practices. The company will notify its users of any significant changes to the policy and will ensure that its employees are informed and trained accordingly.By implementing and maintaining this AML/Compliance Policy, RAMPNOW Sp. z o.o. demonstrates its commitment to preventing money laundering and terrorist financing and ensuring the highest standards of regulatory compliance within the framework of Polish law and international standards.