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AML / KYC POLICY

Paliton s.r.o.

Last updated: 02.12.2025

1. Purpose and Commitment

Paliton s.r.o. (“Paliton”, “we”, “our”) is a Virtual Asset Service Provider incorporated in the Slovak Republic.
We are committed to preventing our services from being used for money laundering, terrorist financing, fraud, sanctions evasion, or any other illegal activity.
This Policy explains how we identify and verify clients, how we monitor transactions, how we manage risk, and how we cooperate with authorities.
Our approach follows Slovak AML legislation, EU AML Directives, FATF standards, and industry best practices applicable to VASPs.
We are committed to preventing our services from being used for money laundering, terrorist financing, fraud, sanctions evasion, or any other illegal activity.
By using our services, Clients confirm that they understand and accept all AML/KYC requirements described in this Policy.

2. Identification and Verification of Clients (KYC)

Before allowing a Client to use our services, Paliton must collect and verify personal data to ensure that the individual is who they claim to be. Verification helps us determine the legitimacy of the Client’s activity and prevents misuse of virtual assets.
Before allowing a Client to use our services, Paliton must collect and verify personal data to ensure that the individual is who they claim to be. Verification helps us determine the legitimacy of the Client’s activity and prevents misuse of virtual assets.

What We Collect:

Before allowing a Client to use our services, Paliton must collect and verify personal data to ensure
that the individual is who they claim to be. Verification helps us determine the legitimacy of the
Client’s activity and prevents misuse of virtual assets.
What We Collect:
• Full name, date of birth, nationality
• Identity document (passport or ID card, as well as driving license)
• Live facial verification
• Information about economic activity and expected use of our services
• Source of funds or source of wealth when necessary
We use third-party verification systems to authenticate documents and support our compliance obligations.

3. Risk Assessment and Ongoing Monitoring

Paliton applies a risk-based approach, meaning that we assess the level of risk associated with each Client and adjust our controls accordingly.

Risk Considerations

We evaluate factors such as:
Client background and geographic location
• Type and volume of expected transactions
• Source of funds and nature of activity
• Whether the Client is a Politically Exposed Person (PEP)
• Exposure to high-risk or sanctioned jurisdictions
Higher-risk profiles require deeper analysis and additional documents.
Monitoring of Transactions
All transactions are monitored continuously. We review both individual activities and overall patterns
to detect:
• Unusual transaction frequency or size
• Use of high-risk wallets or blockchain services known for mixing/tumbling
• Transfers are consistent with the Client’s profile
• Attempts to circumvent controls or hide the identity of the sender/recipient
Links to fraudulent or criminal networks
We employ advanced blockchain analysis tools that allow us to identify risky behavior, potential red flags, or transactions connected to unlawful activities. Paliton may delay, block, or review transactions if risk indicators are detected.

4. Enhanced Due Diligence (EDD)

In situations where the Client or their activity presents increased risk, Enhanced Due Diligence may be required.

EDD is applied, for example, when:
• The Client is from a high-risk country
• Transactions are unusually large, frequent, or complex
• Information provided is inconsistent or cannot be verified
• The Client has historical exposure to suspicious activity
Additional Measures May Include
• Detailed review of the Client’s activity
• Collection of additional documents
• Verification of the source of funds and the source of wealth
• Temporary or permanent transaction limits
If a Client refuses to cooperate or if the risk remains unacceptable, Paliton may suspend or terminate the relationship.

5. Suspicious Activity and Reporting Obligations

If Paliton identifies reasonable grounds to believe that a Client or transaction may be linked to money laundering, terrorist financing, sanctions evasion, fraud, or any other criminal activity, we are required by Slovak and EU law to:

• Conduct an internal analysis
• Report the activity to the competent authority
• Comply with any follow-up information requests
For legal reasons, Clients cannot be informed when a report is submitted.
We may freeze transactions or accounts whenever required by law or when it is necessary to protect our platform and its users.

6. Sanctions and Prohibited Use

Paliton cannot provide services to persons or entities subject to international sanctions or to individuals residing in certain restricted jurisdictions.

We do not serve:
• Sanctioned individuals or entities
• Persons attempting to hide their identity or location
• Clients using fraudulent, forged, or altered documents
• Individuals associated with criminal or high-risk activities
• Clients who refuse to comply with AML/KYC requirements
Paliton reserves the right to refuse, restrict, or terminate services without prior notice if sanctions or serious compliance concerns arise.

7. Record-Keeping and Data Protection

To comply with legal obligation, on securely stores:
• KYC documents and information
• Transaction and monitoring records
• Internal reports and risk assessments
These records are kept for at least five (5) years from the termination of the business relationship or longer if required by applicable laws.
All personal data is processed in accordance with GDPR and Paliton’s Privacy Policy.

8. Cooperation With Authorities

Paliton fully cooperates with Slovak and international supervisory, regulatory, and law-enforcement bodies.
If authorities request specific information, Paliton may provide it as permitted or required by law.
We prioritize transparency, regulatory compliance, and protection of financial integrity.

9. Client Responsibilities

Clients using our services must:

• Provide accurate and truthful information
• Not engage in illegal, suspicious, or high-risk activity
• Respond promptly to KYC/EDD requests
• Inform us of changes in personal data
• Use only their own accounts, wallets, and funds
Any attempt to mislead or deceive the platform may result in account closure and reporting to authorities.

10. Updates to This Policy

Paliton may modify this AML / KYC Policy at any time to reflect regulatory changes or improvements in our compliance framework.
The updated version becomes effective when published on our website.
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