Anti-money laundering

Courts and jurisdictions are divided on whether or not digital and virtual currencies are a currency. Accordingly, digital and virtual currencies may or may not be "money" and, therefore, not subject to anti-money laundering statutes. European Trade Exchange limited has developed a set of anti-money laundering policies that you must agree to abide by. These policies are designed to meet strict standards, including the existence of systems and controls to mitigate the risk presented to any person who accesses or uses the service. This includes, but is not limited to:

• Establishing robust internal policies, procedures and controls that strive to combat any attempted use of BOA for illegal or illicit purposes and to ensure our customers basic protections under consumer protection laws;
• Complying with the applicable regulations and guidance set forth by relevant authorities.
• Filing Suspicious Activity Reports ("SARs");
• Filing Transaction Reports
• Maintaining comprehensive records of orders and other transfers;
• Appointing a Chief Compliance Officer who will be responsible for the implementation and oversight of our KYC/AML Program;
• Executing Know Your Customer ("KYC") procedures on all customers;
• Performing regular, independent audits of our AML program;
• Following record retention requirements; and
• Implementing a formal and ongoing compliance training program for all new and existing employees.

European Trade Exchange, Customer Identity Program (“CIP) or KYC is an important part of our AML program. It helps us detect suspicious activity in a timely manner and prevent fraud. In accordance with this, in order to open an account, your identity must be verified, authenticated, and checked against government watch-lists, including the Office of Foreign Assets Control ("OFAC"). If you are an individual, prior to opening an account, European Trade Exchange will collect, verify and authenticate the following information:

• Email address;
• Mobile phone number;
• Full legal name;
• Social Security Number ("SSN") or any comparable identification issued by government;
• Date of birth ("DOB");
• Home address (not a mailing address or P.O. Box); and
• Additional information or documentation at the discretion of our compliance team.

European Trade Exchange files required reports (i.e. Suspicious Activity Reports) if we know, suspect or have reason to suspect suspicious activities have occurred. A suspicious transaction is often one that is inconsistent with a customer's known and legitimate business, personal activities or personal means. Our compliance department monitors transaction to help identify unusual patterns of customer activity. In addition, all currency transactions over a determined amount are required to be reported to the US government (i.e. FinCEN). Our compliance department maintains records and supporting documentation of all reports filed.

All records are retained for seven (7) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.