Effective date/Last updated: 05.08.2023

This Over-The-Counter (OTC) Policy ("Policy") outlines the terms and conditions governing OTC transactions conducted by Sp. z o.o, a company with the registered address at Piotrkowska str. 116, Lodz, 90-006, Poland, company number 525468892 ("we," "us," "our," or the "Company"). By engaging in OTC transactions with us, you agree to comply with and be bound by this Policy.

Over-The-Counter cryptocurrency exchange, or OTC cryptocurrency exchange, is a framework of financial technology that enables cryptocurrency exchange markets outside a regular exchange.

Coinmaster is an over-the-counter crypto exchange platform that does not require a third party for P2P cryptocurrency exchanges.

Eligibility

OTC transactions are subject to compliance with all applicable laws and regulations.

We may require verification of your identity, source of funds, and adherence to any Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.

Risks and Disclaimers

Engaging in OTC transactions carries inherent risks, including market volatility and regulatory changes.

You acknowledge and assume responsibility for understanding the risks associated with OTC transactions.

Confidentiality

OTC transaction details, pricing, and other sensitive information will be treated as confidential and will not be disclosed to third parties, except as required by law.

KYC Procedure

We carry out the identification and examine you as the Partner with whom we enter in commercial relations prior to establishment of any business relationship, effectively preventing the legalization of proceeds from crime and the financing of terrorism.

We have established a Know-Your-Client (KYC) procedures for OTC Cryptocurrency Exchanges to ensure that identification of all new and existing users was verified with a reasonable level of certainty.

On the onboarding stage, mandatorily before the establishment of business relations and performing any transactions, we identify you by means of documents of evidentiary value and based on information obtained from reliable and independent sources.

During onboarding, you will be requested to complete the onboarding form that includes the following information:

Legal entity

- Company details: company number, registered address, contact person(s) and contact details
- Information regarding ownership structure and UBOs
- Information regarding PEP (Political Exposed Persons)
- Information regarding funds: source of funds and origin of funds, estimated transactions volume in EUR per month, type of business and the purpose of establishing business-relations

Natural person

- name(s) and surname(s)
- personal number
- citizenship
- photograph

Onboarding From should be supported with the following documents:

- Certificate of Incorporation
- Certificate of Good Standing/extract from the Companies register of the respective jurisdiction which contains share allotment details, management details and legal status of the company (not older than 3 months)
- Articles of Association/Organization or Memorandum of Association
- VAT ID (if applicable)
- Register of Shareholders
- Register of Directors
- Copy of Business/Operating License/link to the license on the regulator's website (if applicable)
- Organization Chart / Company Structure
- Certified passport copy and certified utility bills (or equivalent where the address is showed, e.g., driving license) of UBO(s)
- Certified passport copy and certified utility bills (or equivalent where the address is showed, e.g., driving license) of Director(s) and/or Authorized signatory(s)
- Bank statement for the current year
- Financial Statement/Annual Return for the previous and/or the current year
- an identity document/a residence permit/a driving license for identification of natural person

Further, the KYC review will be done on an annual basis to ensure that the documents and information held are kept valid and up to date.

We will retain all records collected in scope and in accordance to this Policy for a period of not less than five years after the termination of business relations.

Additional Information

In any time to assess your risk score we may request any additional information in relation to:

- business activity/business model and financial status of your company and/or UBO;
- detailed information and documental confirmation of the source of funds and actives;
- the purpose of establishment of the business relationship and the purpose of the transaction in question.

Evaluation of provided information

We will examine the information provided by you and categorize you in one of three risk categories: Low risk, Medium risk or High risk.

Depending on the level of risk, Enhanced Due Diligence, allowed transaction limits, information update and transactions monitoring procedures will be applied in future.

We will perform screening against the following sanctions lists:

1. UN Sanctions;
2. EU Sanctions;
3. Sanctions administered by the Office of Foreign Assets Control (“OFAC”);

In case yours dossier is categorized as Prohibited, the process of establishment of business relations is stopped and all the negotiations are ceased.

Reporting

The Compliance Officer is the person, duly authorized by us, whose duty is to ensure the effective implementation and enforcement of this Policy as well as AML Policy.

After the Compliance Officer has received the internal suspicious report, he will review it and take steps to validate the suspicion actions in order to judge whether or not this should be communicated to the respective government agency.

Dispute Resolution

Any disputes arising from or related to OTC transactions will be resolved in accordance with the governing laws of Poland.

You may submit any of queries using the following email: [email protected] and we will revert to you in due course

Changes to this Policy

We may update this OTC Policy from time to time. The latest version will be posted on our website under section “Last updated”.