Anti-Money Laundering and Know Your Customer Policy · Version 1.0 · Effective Date: 1 April 2026

1. Introduction and purpose

PowrAI Digital Exchange sp. z o.o. ("PowrAI"), operator of Finquest Exchange, is committed to the highest standards of AML and CTF compliance as required under its VASP licence (RDWW-1725) issued by Dyrektor Izby Administracji Skarbowej w Katowicach.

This policy establishes procedures for: (i) identifying and verifying users (KYC); (ii) monitoring transactions; (iii) reporting suspicious activity; and (iv) record keeping.

2. Legal framework

• Polish Act on Counteracting Money Laundering and Terrorism Financing (Ustawa z 1 marca 2018 r.) — primary framework;
• Directive (EU) 2018/843 (5AMLD) and Directive (EU) 2015/849 (4AMLD);
• Regulation (EU) 2023/1113 (Transfer of Funds Regulation — Travel Rule);
• MiCA — Regulation (EU) 2023/1114 (applicable CASP obligations);
• FATF Recommendations for Virtual Asset Service Providers;
• EU and UN Sanctions Regulations; OFAC guidelines;
• GDPR — Regulation (EU) 2016/679.

3. AML officer

PowrAI has appointed a dedicated AML Compliance Officer responsible for:

• Overseeing implementation and review of this policy;
• Acting as primary contact for regulatory authorities on AML/CTF matters;
• Reviewing and approving Suspicious Activity Reports (SARs);
• Ensuring staff training; conducting periodic risk assessments.

AML Officer contact: compliance@finquestexchange.com

4. Customer due diligence (CDD) — KYC procedures

4.1 Standard CDD

4.2 Enhanced due diligence (EDD)

Required for: Politically Exposed Persons (PEPs); users transacting above applicable thresholds; users from FATF high-risk jurisdictions; corporate accounts; and elevated-risk profiles. EDD includes source of funds/wealth documentation, ownership structure for corporates, and senior management approval.

4.3 Ongoing monitoring

• Periodic re-verification (at minimum annually, or upon risk trigger);
• Continuous transaction monitoring for unusual patterns;
• Automated PEP and sanctions screening at onboarding and ongoing;
• Adverse media screening for high-risk profiles.

5. Risk-based approach

6. Transaction monitoring and SARs

6.1 Red flags (non-exhaustive)

• Transactions inconsistent with the user's stated profile or source of funds;
• Rapid deposit-and-withdrawal without trading activity (pass-through);
• Structuring — multiple transactions just below reporting thresholds;
• Wallets associated with known illicit activity (blockchain analytics);
• Use of VPNs, Tor, or anonymisation tools;
• Account-sharing indicators or multiple accounts per individual.

6.2 Suspicious activity reports

Upon identification of suspicious activity, PowrAI will: document and file a SAR with the Polish Financial Intelligence Unit (GIIF — Generalny Inspektor Informacji Finansowej); not notify the user (tipping-off prohibition); freeze or restrict the account; and retain all related records.

7. Travel rule compliance

In accordance with Regulation (EU) 2023/1113 and FATF Recommendation 16:

• Transfers above EUR 1,000: full originator and beneficiary KYC data transmitted to receiving VASP/CASP;
• Transfers below EUR 1,000: basic originator identification collected and retained.

8. Record keeping

9. Contact