AML/KYC Policy

1. Company
Simpledo Finansal Teknolojiler A.S. (Simpledo) is established in accordance with the laws of the Republic of Turkey and continues its commercial life in full compliance with the laws.

2. Purpose
The purpose of this policy is to establish the general framework by Simpledo to combat money laundering and terrorism financing.

Simpledo is committed to high standards of money laundering and compliance with the financing of terrorism (AML / CFT), and aims to ensure that its management and employees comply with these standards in preventing the use of its products and services for money laundering or terrorist financing.

Simpledo takes reasonable measures to control and limit the risk of money laundering / terrorism financing, including the allocation of appropriate tools.

Simpledo's AML program is designed to be compatible with: European and Turkish laws and regulations regarding AML / CFT, Directives of the European Parliament and of the Council on the prevention of the use of the financial system for the purpose of money laundering or terrorist financing

3. AML Organizational Structure
3.1 In accordance with the AML / CFT legislation, Simpledo has appointed “highest level�? responsible among the Board of Directors.

Additionally, an Anti-Money Laundering Compliance Officer is responsible for enforcing the AML policy and company procedures. The Anti-Money Laundering Compliance Officer is a Simpledo employee charged with ensuring compliance with the AML Policy.

3.2 Every major change in Simpledo's AML policy is approved and carefully monitored by Simpledo's Board of Directors.

3.3 Simpledo periodically audits whether it complies with company policies and procedures.

4. Identification and Verification (KYC)
Formal identification of customers at entry into business relationships is a vital element in both money laundering regulations and KYC policy.

-By determining and confirming the valid identity and address information of the (potential) customers, which are accepted by the legal authorities, before the transaction facility and while the continuous business relationship is maintained.

-It performs the necessary checks and takes additional measures regarding the possibility of customers being on the national/international sanction lists.

-Simpledo does not establish a business relationship and does not perform the requested transaction in cases where it cannot identify or obtain sufficient information about the purpose of the business relationship; terminates the business relationship if the required identification and confirmation cannot be made due to doubts about the adequacy and accuracy of the previously obtained customer identification information.

Within the scope of standard customer identification measures, the determinations that should be made by our company as a minimum are given below:

-Customer identity, address confirmation

- Screening of customers against the risks of being included in international sanctions lists (including country risk assessment)

- Determining whether the customer is politically influential or related to the political influencer,

- Investigating whether the customer is related to very high-risk countries accepted within the scope of international sanctions,

- Detection of whether or not to act on behalf and / or on behalf of someone else,

- Simpledo only serves Individuals. Simpledo does not serve Organizations or Business Entities. Increased customer measures are also applied for customers deemed risky by the Simpledo as a result of the risk assessment to be made at the time of customer acceptance or afterwards. Within the scope of increased customer measures, the determinations that must be made by Simpledo at least are given below:

- Before allowing crypto swap transactions, Simpledo may ask the customer firstly to purchase Crypto Coins with Bank Issued Credit Card or Debit Card.

- Identification of the customerwealth and confirmation of the document when necessary,

- Detection and confirmation of the source of income,

- Determination of whether the funding sources and/or capital belonging to the customer are easily and satisfactorily verified.

5. Risk Assessment

Simpledo monitors activities of its customers and performs risk analysis.

For this purpose,Simpledo monitors:

- Geographical location of the customer (country, region, etc.).

- Certain products and services provided to the customer.

- Whether the client has political influence,

- If Individuals included in national and international sanction lists,

- Type and frequency of transactions performed by the customer,

- Total amount of a single transaction or Daily, Weekly, Monthly linked transaction reaches certain level. Persons whose financial transactions will not be mediated within the scope of the risk assessment methodology are listed below:

Persons whose financial transactions will not be mediated within the scope of the risk assessment methodology are listed below:

- Persons that avoid giving information and documents and entering into records,

- Individuals who want to open an account anonymously or under a pseudonym,

- Individuals included in national and international sanction lists,

- Individuals located in or affiliated with countries (risky countries) that do not have adequate regulations on laundering the proceeds of crime and preventing the financing of terrorism,

- Political influencers.

The list provided above is not an exhaustive one and Simpledo monitors customers’ transactions daily to establish whether to report the customers and to consider their actions as suspicious.

6. Ongoing Process Monitoring
Within the scope of preventing laundering proceeds of crime and financing of terrorism, the Firm performs a continuous monitoring.

7. Internal Controls

7.1. Notification of Suspicious Transactions

Within the framework of the services provided by Simpledo, in cases that raise suspicion regarding money laundering and financing of terrorism, the transactions determined as suspicious transactions as a result of the necessary investigations are reported to the Financial Crimes Investigation Board (MASAK) in accordance with the current legislation, regardless of the amount.

7.2. Record Keeping Simpledo keeps documents and records related to identification for ten years from the last transaction date and submits them to the authorities if requested.

7.3. Training Training activities areorganized for all Simpledo personnel, either locally or remotely.

- Introduction of MASAK regulations and AML/CFT,

- Internal compliance officer information and suspicious transaction reporting channels.