Policy Overview

Calypso Internet Technologies Limited presents to your attention this AMLTF Policy (hereinafter referred to as the “Policy”). Please note that the Client automatically accepts the terms of this Policy after accepting the Basic Offer, which is available on the Company’s official website: calypsotechnolimited.company.

Terminology

1. Responsibilities of the Company

1. Compliance with Regulations: Comply with the requirements of state authorities of the Client’s residence state, as well as international standards related to combating illegal trade and AMLTF.
2. Legal Adherence: Company undertakes to comply with legislation of the country whose jurisdiction it operates under, as well as international standards for combating illegal trade and AMLTF, including FATF recommendations and EU AML directives.
3. Confidentiality: Keep confidential information relating to corporate standards and Company policies in the field of AMLTF, unless otherwise provided by legislation.
4. Government Collaboration: Collaborate with government agencies in the field of collection of information, implementation of preliminary investigative actions, court proceedings and the use of coercive measures regarding any facts that indicate a violation of AMLTF requirements.
5. Procedural Confidentiality: Not to inform Clients and other persons on the details of AMLFT procedures, as this prevents the correct implementation of AMLFT measures.
6. Internal Checks: The Company carries out regular checks of persons, including own employees who work under civil contracts. Any suspicious information about such persons is provided to the administrative bodies of the Company for making a decision, depending on the circumstances, to prevent or initiate an investigation regarding this person and, if necessary, impose sanctions.
7. Enhanced Due Diligence: Implement enhanced due diligence for high-risk investment products including Pre-IPO investments, hedge fund participations, and cross-border real estate transactions.

2. Responsibilities of the Client

1. Regulatory Compliance: Comply with the requirements of legislation of the Client’s residence state, as well as international standards related to combating against illegal trade and AMLTF.
2. Legitimacy Guarantee: Guarantee and, if necessary, confirm the legitimacy of the origin of money and other assets used for investment purposes, confirm ownership of property or rights to use or own property.
3. Prohibition of Illegal Operations: Not to engage directly or indirectly in illegal operations using information and telecommunication technologies, as well as audiovisual and other programs.
4. Contractual Obligations: Fulfill obligations to the Company in accordance with legislation of the country of residence, international conventions and other international standards, this Policy and other corporate rules of the Company.
5. Documentation Requirements: At the request of the Company, submit documents that certify the status of the Client for identification.
6. Political Exposure Disclosure: Disclose any political exposure status (PEP) of beneficial owners, directors, or senior management.
7. Translation and Legalization: Present documents in originals or copies with a certified translation into the language of the country of residence if the identifying documents of the Client are executed in whole or in part in a foreign language.

3. Client Authentication

In addition to the Client identification procedures provided for by this Policy, the Company carries out:

• Comprehensive verification of clients who are legal entities, including anti-corruption examination of constituent documents
• Customer survey (by sending profiles) including investment experience and objectives
• Oral survey with recording information in the Client’s profile
• Identification of clients who act on behalf of other clients as a representative
• Verification of qualified investor status through financial documentation
• Source of funds and wealth verification for investment capital
• Other activities the Company considers appropriate to achieve the objectives of this Policy

Suspicious Activity Monitoring

Company has the right to track information about the Client’s transactions to identify unusual and suspicious activities including:

• Unusual investment patterns inconsistent with stated objectives
• Rapid movement of funds between different investment products
• Investments inconsistent with client’s profile or known legitimate activities
• Use of complex structures to obscure beneficial ownership
• Investments in products inconsistent with their investor profile
• Use of third-party funds without proper authorization or disclosure

If any suspicious activity is detected, the Company must collect, process and analyze additional internal or external information, contact the law enforcement authorities of the respective states and freeze the account, depending on circumstances.

4. Deposit and Withdrawal of Funds

1. Payer Identification: If the Client deposits money into the account, then he acts as a payer. In this case, the name of the payer must necessarily coincide with the name of the Client. Third parties are not allowed to deposit money into the Client’s account except through properly documented and approved structures.
2. Account Consistency: For bank transfers and online transfers, the deposit and withdrawal accounts must coincide unless otherwise approved through enhanced due diligence procedures for investment structures.
3. Withdrawal Verification: When withdrawing funds, the name of the Client who withdraws money must coincide with the name of the Client acting as the owner of account which the money is withdrawn from.
4. Transaction Monitoring: All investment subscriptions and redemptions are subject to source of funds verification and transaction monitoring.

5. Due Diligence Policy

Together with the Know Your Customer Policy, the Company carries out due diligence, checking the competitiveness and rating of Client among similar structures. Due diligence is used to prevent corruption that directly or indirectly affects the violation of AMLTF requirements.

Product-Specific Due Diligence

6. Ongoing Monitoring and Record Keeping

Ongoing Monitoring

The Company will conduct ongoing monitoring of client relationships including:

• Regular review of client transactions and investment activities
• Periodic update of client identification information
• Monitoring for changes in risk profile
• Review of investment performance against stated objectives

Record Keeping

The Company will maintain records of all client identification documents, account files, and business correspondence for a minimum period of five years after the termination of the business relationship.

All records will be maintained in accordance with applicable data protection regulations and available for inspection by competent authorities.

Training and Awareness

The Company will provide regular training to employees on AML/CFT procedures, with specific focus on alternative investment products and associated risks. Training will be updated regularly to reflect changes in regulations, products, and emerging risks.