1. Introduction

Konto.com Exchange, operated by Rondo Services Sp. z.o.o. (hereinafter “Konto.com Service Provider”), is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. The Service Provider applies robust and risk-based measures to prevent, detect, and mitigate money laundering, terrorist financing, fraud, and other forms of financial crime.

Konto.com Service Provider complies with all applicable anti-money laundering and counter-terrorist financing (AML/CTF) legislation, including European Union directives and regulations, Polish and Romanian national laws, and international standards issued by the Financial Action Task Force (FATF), as well as obligations arising under Markets in Crypto-Assets Regulation and EU Travel Rule Regulation.

Crypto-assets present specific risks, including pseudonymity, cross-border transferability, and technological complexity. Konto.com Service Provider implements enhanced safeguards to address these risks and to ensure that its platform is not used for illicit purposes.

Konto.com Service Provider also implements operational and security measures aligned with applicable ICT risk management and operational resilience requirements, including those arising under the Digital Operational Resilience Act (DORA).

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2. AML, CTF and Sanctions Compliance Framework

Konto.com Service Provider applies a risk-based approach to AML/CTF compliance, meaning that the level of control and due diligence applied is proportional to the level of risk identified.

The AML/CTF framework includes, but is not limited to:

• Customer identification and verification (Know Your Customer – KYC);
• Ongoing monitoring of transactions and business relationships;
• Risk profiling and classification of customers;
• Screening of clients, transactions, counterparties, and wallet addresses against international sanctions lists and internal risk indicators;
• Identification of politically exposed persons (PEPs), their family members, and close associates, and the application of enhanced due diligence (EDD);
• Compliance with obligations relating to transfers of funds and crypto-assets, including Travel Rule requirements;
• Detection, investigation, and reporting of suspicious activities;
• Implementation of internal controls, governance, and compliance oversight.

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Konto.com Service Provider maintains a zero-tolerance approach to financial crime and may refuse, restrict, or terminate services where required to comply with applicable laws or internal risk policies.

3. Customer Due Diligence (KYC)

Konto.com Service Provider conducts customer due diligence prior to establishing a business relationship and on an ongoing basis throughout the lifecycle of the account.

This includes:

• Identification and verification of the client’s identity;
• Identification of beneficial owners where applicable;
• Assessment of the purpose and intended nature of the business relationship;
• Verification of payment methods and ownership of funds.

Clients are required to provide accurate, complete, and up-to-date information. Konto.com Service Provider may request additional information or documentation at any time to comply with legal and regulatory obligations.

Where higher risks are identified, enhanced due diligence measures may be applied, including but not limited to:

• verification of source of funds and source of wealth;
• increased monitoring of transactions;
• additional verification steps.

Failure to provide required information or documentation may result in the refusal of services, suspension of the account, or termination of the business relationship.

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4. Transaction Monitoring and Financial Crime Prevention

Konto.com Service Provider performs continuous monitoring of transactions and user activity to detect unusual patterns, suspicious behaviour, or potential violations of applicable laws.

Monitoring includes, among others:

• identification of complex or unusual transactions;
• detection of transactions involving high-risk jurisdictions;
• monitoring of rapid movement of funds or crypto-assets;
• analysis of behavioural and transactional patterns.

Where necessary, Konto.com Service Provider may delay, reject, or suspend transactions pending further review.

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5. Reporting Obligations and Cooperation with Authorities

In accordance with applicable laws, Konto.com Service Provider reports suspicious transactions and activities to competent authorities, including financial intelligence units (FIUs).

Konto.com Service Provider is legally prohibited from disclosing the existence of such reports or investigations to the Client (“tipping-off” prohibition).

Konto.com Service Provider fully cooperates with regulatory, supervisory, and law enforcement authorities in the prevention and investigation of financial crime.

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6. Sanctions and Screening Measures

Konto.com Service Provider ensures compliance with international sanctions regimes, including those imposed by the European Union, the United Nations, and other relevant authorities.

Clients, transactions, counterparties, and wallet addresses may be screened against:

• sanctions lists;
• watchlists and enforcement databases;
• internal risk indicators and monitoring systems.

Where a match or elevated risk is identified, Konto.com Service Provider may restrict, suspend, or terminate the business relationship and take any action required by law.

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7. Record Keeping and Data Protection

Konto.com Service Provider retains records of customer identification, transactions, and related data for the period required under applicable law, including Polish and Romanian AML legislation and EU regulations.

All records are stored securely and protected against unauthorized access, alteration, or loss, in accordance with applicable data protection laws, including GDPR.

Customers may exercise their rights in accordance with the GDPR as detailed in the Privacy Notice.

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8. Use of Third-Party Service Providers

Konto.com Service Provider may rely on third-party service providers, including payment institutions, liquidity providers, technology providers, and compliance solution providers, for the performance of certain AML/CTF controls and operational processes.

Notwithstanding such reliance, Konto.com Service Provider remains fully responsible for compliance with applicable legal and regulatory obligations.

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9. Internal Governance and Continuous Improvement

Konto.com Service Provider maintains internal policies, procedures, and controls designed to ensure effective AML/CTF compliance and regularly reviews and updates its framework to reflect:

• changes in legal and regulatory requirements;
• emerging financial crime risks;
• technological developments.

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10. Reporting Concerns

Any concerns regarding potential non-compliance or suspicious activity may be reported to: legal@konto.com

All reports will be handled confidentially and in accordance with applicable legal requirements.

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