Anti-Money Laundering (AML) Policy

This Anti-Money Laundering (AML) Policy (hereinafter referred to as "the Policy") governs the activities of Pulmp Exchange in its commitment to combat money laundering and terrorist financing. Pulmp Exchange ensures adherence to global standards and national regulations to promote a safe, transparent, and compliant operational environment.

1. Terms and Definitions

1. Pulmp Exchange: The entity providing users with services for exchanging digital and electronic currencies.
2. Service: The platform that facilitates internet-based transactions for the exchange, purchase, and sale of digital and/or electronic currencies.
3. User: Any natural person engaging with Pulmp Exchange’s services.
4. Digital Currency: Blockchain-based assets such as Bitcoin, Ethereum, Litecoin, and others.
5. E-Currency: Digital funds held within electronic payment systems.
6. Money Laundering: The process of concealing or disguising the origins of money or assets obtained through illegal means to make them appear legitimate.
7. Terrorist Financing: The collection or provision of funds intended to support acts of terrorism.
8. High-Risk Jurisdictions: Countries or regions identified as having inadequate measures against money laundering and terrorist financing.

2. Commitment to AML Compliance

Pulmp Exchange prioritizes adherence to national and international AML standards, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations
• EU’s Sixth Anti-Money Laundering Directive (6AMLD)
• National legislation such as the Proceeds of Crime Act 2002 and the Anti-Terrorism Act 2008

To mitigate risks and comply with legal obligations, Pulmp Exchange has adopted robust internal policies and procedures, including:

2.1 Know Your Customer (KYC) Policy

Pulmp Exchange enforces mandatory identity verification for all users before allowing access to its services. Users are required to submit:

• A valid government-issued ID (e.g., passport, driver’s license).
• Proof of residence (e.g., utility bill or bank statement no older than three months).
• Photographs of payment methods (e.g., credit cards with only the last four digits visible).

Failure to comply with KYC requirements may result in account suspension or termination.

2.2 Continuous Transaction Monitoring

To detect and prevent suspicious activities, Pulmp Exchange employs:

• Risk-Based Approaches (RBA): Assigning verification tiers based on transaction volume and user activity.
• Automated Alerts: Identifying unusual transaction patterns that may indicate illegal activities.
• Designated Money Laundering Reporting Officer (MLRO): Ensuring operational compliance with AML standards.

2.3 Verifying the Source of Funds

Pulmp Exchange may require users to provide additional documentation to validate the origin of funds, including:

• Bank account statements
• Blockchain transaction details
• Contracts or invoices related to the source of funds

3. Enforcement and Monitoring

Pulmp Exchange takes a zero-tolerance approach to money laundering and terrorist financing by implementing the following measures:

1. Suspicious Activity Reporting (SAR): Reporting identified risks to the relevant authorities as per national and international regulations.
2. Account Restrictions: Temporary or permanent suspension of accounts involved in illicit activities.
3. Sanctions Compliance: Ensuring compliance with international sanctions by restricting users from jurisdictions subject to embargoes or high-risk classifications.

4. High-Risk and Restricted Jurisdictions

Pulmp Exchange restricts access to its services for users from jurisdictions with a heightened risk of money laundering or terrorist financing. These include:

• High-Risk Countries: Afghanistan, Cuba, Iran, North Korea, Syria, Venezuela, and others as per FATF advisories.
• Disputed Territories: Crimea, Donetsk People's Republic, Luhansk People's Republic, and similar regions.

Funds from such jurisdictions are blocked and returned to the originating source whenever possible.

5. IT and Data Security

Pulmp Exchange invests in cutting-edge IT infrastructure to ensure secure transactions and data protection, including:

1. Encryption Standards: End-to-end encryption for data storage and transmission.
2. Multi-Factor Authentication (MFA): Ensuring only authorized users can access their accounts.
3. Regular Audits: Conducting routine evaluations of security protocols to identify vulnerabilities.

6. Training and Awareness

To maintain high standards of compliance, Pulmp Exchange conducts regular training for its staff, focusing on:

• Identifying and responding to money laundering risks.
• Updates on AML regulations and compliance practices.
• Effective use of monitoring tools to identify suspicious transactions.

7. User Responsibilities

Users are required to:

• Provide accurate and complete information during KYC processes.
• Avoid engaging in prohibited activities, such as using the service to conduct illegal transactions or evade sanctions.
• Notify Pulmp Exchange of any suspicious activity detected in their accounts.

Non-compliance with these requirements may result in service restrictions or reporting to authorities.

8. Collaborative Efforts with Authorities

Pulmp Exchange works closely with local and international authorities to support the investigation of money laundering or terrorist financing cases. This includes sharing user data in response to lawful requests and cooperating with AML task forces.

9. Review and Updates

Pulmp Exchange regularly reviews its AML Policy to ensure alignment with evolving regulations and industry standards. Updated policies will be published on the platform, and users are encouraged to review them periodically.

10. Penalties for Violations

Pulmp Exchange enforces strict penalties for violations of this Policy, including:

1. Account Termination: Immediate closure of accounts involved in illegal activities.
2. Legal Action: Referral of cases to law enforcement agencies for prosecution.
3. Financial Penalties: Imposing fines for non-compliance where permissible by law.

11. Contact Information

For inquiries or reporting suspicious activity, contact Pulmp Exchange at support@pulmpexchange.com.