Anti-Money Laundering Policy

1. Introduction

Bitjust LTD ("Bitjust", "we", "us" and/or "our(s)") Anti-Money Laundering Policy ("AML Policy") is designed to prevent and mitigate possible risks of Bitjust being involved in any kind of illegal activity.

This document is a summary of key principles from Bitjust's internal policy and should not be viewed as the full AML Policy.

Domestic and international regulations require Bitjust to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity.

This AML Policy covers the following matters: appointing an Anti-Money Laundering Compliance Officer (AMLCO) and ensuring employees know how to report suspicious activity; identifying the responsibilities of senior managers and providing them with regular information on money laundering risks; training employees on their anti-money laundering responsibilities; documenting and updating anti-money laundering policies, controls and procedures; introducing measures to ensure that the risk of money laundering is taken into account in day-to-day business operations; forwarding all sustained suspicions to the appropriate authority; promptly responding to all communication from the appropriate authority.

2. Anti-Money Laundering Compliance Officer

The Anti-Money Laundering Compliance Officer ("AMLCO" or "the Compliance Officer") is ultimately responsible for implementing regulations concerning Anti-Money Laundering.

The AMLCO is a person of authority with access to any and all relevant information for the performance of their duties.

You can contact Bitjust's AMLCO department by emailing us at: compliance@bitjust.co

3. General Requirements

Before Bitjust can execute any transaction for any new user, the following procedures must be in place: AML procedures including user identification, record-keeping, discovery and monitoring of unusual or suspicious transactions, and internal and external reporting and control; ensuring that all employees know and understand their responsibilities and AML procedures; ensuring that appropriate training is undertaken; all relevant requests from outside sources are forwarded directly to the AMLCO.

4. Identity Verification

Whenever Bitjust requests and receives supporting documents related to a new user's identity, we must be satisfied that they demonstrate the existence of the user as a real natural or legal person and that the user is indeed who they claim to be.

User identification information will be collected, securely stored, shared and protected strictly in accordance with the Bitjust Privacy Policy and applicable data protection regulations.

5. Transaction Monitoring

Constant monitoring of user accounts and transactions is an essential element in effectively controlling the risk of money laundering and terrorist financing. The AMLCO is responsible for maintaining and developing the ongoing monitoring process.

6. Risk Assessment

Bitjust applies appropriate measures and procedures by adopting a risk-based approach, focusing efforts in areas where the risk of money laundering and terrorist financing appears comparatively higher. The AMLCO monitors and evaluates the effectiveness of these measures on an ongoing basis.

The risk-based approach adopted by Bitjust recognizes that money laundering and terrorist financing threats vary across users, countries, services and financial instruments; allows differentiation between users in a way that matches the risk of their particular activity; allows Bitjust to apply its own approach in formulating policies, procedures and controls in response to particular circumstances; promotes prioritization of effort and actions in response to the likelihood of money laundering and terrorist financing occurring through the use of our Services.

7. Sanctions

Bitjust does not carry out transactions with individuals or legal entities from countries under international sanctions or from other restricted jurisdictions.

We screen all new and existing users against the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

Bitjust does not provide services to individuals or legal entities that are residents of the following jurisdictions:

Afghanistan, Burundi, Central African Republic, Congo, Cuba, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Libya, Mali, Myanmar, Nicaragua, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, Zimbabwe.

The above list may be updated at any time with or without updating this AML Policy by a decision of the Compliance Officer.

This AML Policy is written and is subject to change only in English. In the event of any discrepancy in translation, the English version shall prevail.