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Rakiku Technologies Ltd.

Due Diligence Manual

2023

Licenses
  1. Financial services providing a virtual currency wallet service:
    Number
  2. Financial services providing services of exchanging a virtual currency against a fiat currency:
    Number
Disclaimer
This AML and KYC Manual is a reference for the compliance team and back office of Rakiku Technologies Ltd.
This Manual is for internal use only.
  1. Obligation to take due diligence measures

    2. Rakiku Technologies Ltd. shall take due diligence measures

    1. Upon establishment of a business relationship; upon carrying out or mediating on an occasional basis transaction the value of which exceeds 15,000 euros or an equal amount in another currency.
    2. Upon suspicion of money laundering or terrorist financing, regardless of any derogations, exceptions or limits provided by law; when the documents or data gathered earlier while identifying and verifying a person or while updating the respective data prove to be deficient or there is doubt about the veracity of the documents or data.
  2. Due Diligence Measures

    3. To perform the due diligence measures, Rakiku Technologies Ltd. shall take the following due diligence measures in economic and/or professional activities:

    1. Identification of the customer or the person participating in the transaction on the basis of documents and data submitted by him or her.
    2. Verification of the submitted information on the basis of information obtained from a reliable and independent source.
    3. Identification and verification of the representative of the natural person or of the legal person and the right of representation;
    4. Identification of the beneficial owner, including gathering information about the ownership and control structure of the legal person, trust, civil law partnership or other contractual legal arrangements on the basis of information provided in pre-contractual negotiations or obtained from another reliable and independent source;
  3. Monitoring of Information

    4. Constant monitoring of the business relationship, including:

    1. Monitoring transactions carried out during the business relationship.
    2. Regular verification of data used for identification.
    3. Updating relevant documents, data or information and, if necessary:
    4. Identification of the source and origin of funds used in the transaction.
  4. Simplified Due Diligence:

    5. Rakiku Technologies Ltd. will take simplified due diligence measures if:

    1. A person participating in a transaction carried out in economic or professional activities or participating in a professional operation or a person using a professional service, or:
    2. Legal person governed by public law founded in Lithiuania;
    3. Governmental authority or another authority performing public functions in Lithiuania or a contracting state of the European Economic Area;
    4. Authority of the European Community:
    5. Company of a contracting state of the European Economic Area or a third country, which is subject to equal requirements.
    6. Credit institution or a financial institution, a credit institution or a financial institution located in a contracting state of the European Economic Area or in a third country.
    7. Written contract has been concluded with a customer for an indefinite period.
    8. Payment is made through the account of a customer or a person participating in a transaction, which has been opened in a credit institution or the branch of a foreign credit institution registered in the Lithiuanian commercial register or in a credit institution that has been registered or has its place of business in a
      contracting state of the European Economic Area
    9. Obligated person has established by rules of the internal procedure beforehand that the annual total value of the performance of financial obligations arising from transactions of such type does not exceed the maximum limit of 15,000 euros;
  5. Enhanced Due Diligence:

    6. Rakiku Technologies Ltd. will take enhanced due diligence measures if:

    1. Upon identification or verification of a person suspicion arises regarding the truthfulness of the data or authenticity of the documents submitted or regarding the identification of the beneficial owner or beneficial owners.
    2. A person participating in a transaction performed in economic or professional activities, a person participating in a professional operation, a person using a professional service or a customer is a PEP.
  6. Enhanced Measures Include:
    1. Identification and verification of a person on the basis of additional documents, data or information, which originates from a reliable and independent source or from a credit institution or the branch of a credit institution registered in the Lithiuanian commercial register or from a credit institution, which has been
      registered or has its place of business in a contracting state of the European Economic Area.
    2. Taking additional measures for the purpose of verifying the authenticity of documents and the data contained therein, among other things, demanding that they be notarised or officially authenticated or confirmation of the correctness of the data by the credit institution specified in the clause which issued the
      document;

APPENDIX I – Request for Privacy Information – Natural Client

APPENDIX II – Request for Privacy Information – Non-Natural Client

APPENDIX III – Request to Inform the Management on PEP

APPENDIX IV – Request to Inform the Management of Declined Client