AML Program is designed to identify and manage the risks that Quantum Pulse Systems s.r.o.
(“Quantum Pulse Systems s.r.o.” or “Company”) may face in the course of doing business.
Accordingly, Quantum Pulse Systems s.r.o. follow a set of procedures aimed at preventing money laundering or terrorist financing.

General
AML rules mean procedures and rules to prevent financial abuse of the system based on Act on Some Measures Against Legalization Proceeds from Crime and Terrorist Financing (hereinafter referred to as the “AML Act”); On Certain Requirements Against the Legalization of Proceeds from Criminal Activity a the financing of terrorism (hereinafter referred to as the 'AML Decree').
The authorized authority in the area of combating money laundering and terrorist financing in the Czech Republic is the Financial Analytical Unit of the Ministry of Finance (hereinafter referred to as FAU MF), whose main task is to examine suspicious transactions reports received from obliged entities on the basis of notification.

The Quantum Pulse Systems s.r.o. is governed by this AML Policy together with the General Terms and Conditions and other policies. The AML Policy governs how we prevent the legalisation of proceeds from criminal activity and financing of terrorism.
Definitions used in this AML Policy have the meaning defined in the General Terms and Conditions unless expressly stated otherwise.

Why We Identify
In accordance with the Act we take measures against the legalisation of proceeds from criminal activity and financing of terrorism. We fulfil obligations stipulated by legal regulations in this field so as to prevent the misuse of the financial system for the legalisation of proceeds from criminal activity and financing of terrorism and so as to establish conditions for detecting such conduct.
The Act obliges us to meet obligations in relation to Clients. The above obligations include in particular performing identification of Clients and performing due diligence of Clients in cases stipulated by the Act.

Inspection of the Clients
Company carries out Clients checks pursuant the AML Act. The Company automatically and manually checks each Client using internal KYC services. By conducting Clients Checks, we obtain the information we need to assess whether or not a trade is suspicious.

Clients Verification (KYC)
For each client, we perform verification in national and international databases. We verify the truth of the information provided, compliance with card association rules, client identification verification, and other relevant facts. We continuously monitor sanction lists and sanctioned countries as well as individual transactions.

Sending or receiving transfers with the help of third parties are strictly prohibited and the company reserves the right to block attempts at such sending or receiving.

When we define
We always identify Clients before providing services Quantum Pulse Systems s.r.o. Positive and undeniable identification is an inevitable condition for the beginning of cooperation.

How We Identify
Identification is performed distance, without the physical presence of the Client pursuant to of the AML Act.

Required documents:
- identity document of the client; bank account statement in the name of the client proof proving the address of the client. The Company reserves the right to request any additional necessary information or documentation regarding the Client's data.
- PEP report (statement that the client is not a politically exposed person)

Politically exposed person: (a) a natural person who is or has been in a significant public office with a national one; or regional importance, such as the head of state, prime minister, head of central government a public administration body or its representative (deputy, state secretary), member of parliament, member the governing body of the political party, the head of territorial self-government, the judge of the Supreme court, constitutional court or other supreme judicial authority against whose decision in general (with some exceptions) remedies cannot be applied, a member of the Bank Board of the Central Bank, high officer of the armed forces or corps, member or deputy member (if legal) person) a statutory body of a business corporation controlled by the state, an ambassador or a chief executive diplomatic missions, or a natural person who performs similar functions in or on a similar basis another state, in an EU institution or in an international organization;
(b) a natural person who is a close person to the person referred to in point (a);
(c) a natural person who is a partner or beneficial owner of the same legal person; where appropriate, a trust fund or other legal arrangement without a legal personality, such as the person referred to in point (a) or known to SF to be in any other close person business relationship with the person referred to in point (a);
(d) a natural person who is the beneficial owner of a legal person or, as the case may be, a trustee fund or other similar legal arrangement without legal personality of which SF is concerned known to have been created for the benefit of the person referred to in point (a).

The Company requests Personal data Client:
- Face ID
- Date of birth
- identification number
- Gender
- Place of birth

Permanent or other residence: identification of the relevant residence in order to be traceable - and existing (verifiable on the Internet), and should be verifiable in the relevant documents. Authority issuing the identity document: the entry is recorded if it is included in the identity card.
Required types of identity card: identity card, passport, driving license, identity card, foreigner's residence permit, etc.

These types of ID cards can only be accepted if they meet the following requirements:
- it is a valid and government-issued document;
- the card is not damaged beyond the normal level of wear (eg missing sheets, glued, rewritten, illegible etc.);
- the holder 's portrait must correspond to the true form of the holder and must be sufficiently clear or undamaged to allow the holder to be sufficient the likelihood of identification;
- it is a document from which it can be clearly identified which authority of which State has issued it;
- it is a document which for no reason raises doubts as to its authenticity.
In case of detection of false information, Quantum Pulse Systems s.r.o. reserves the right to block account, as well as terminate interaction with this Client.Reporting of Unusual/Suspicious Transactions/Activity

In case of detection of false information, Quantum Pulse Systems s.r.o. reserves the right to block account, as well as terminate interaction with this Client.

Quantum Pulse Systems s.r.o. undertakes to conduct an additional detailed check and, if a financial violation has been committed, to report this to the governing authority.

Quantum Pulse Systems s.r.o. undertakes to report customer data to the governing authority if the amount of transactions exceeds the limit of 10 000 dollar USA or the equivalent amount in foreign or virtual currency.

Quantum Pulse Systems s.r.o. undertakes to take into account the risk status of the Client, its origin, country, business activity and the nature of the funds when checking the Client's transactions.

Quantum Pulse Systems s.r.o. reserves the right to block account, Client's account in the following cases: Upon detection of a violation of any of the requirements presented in AML Program;

If the Client's action is stopped by the fraud prevention system due to confirmed financial fraud.
If the Client's action is stopped during a manual fraud prevention check by one of the authorized employees.
If the Company Quantum Pulse Systems s.r.o. has other weighty reasons that have raised suspicions about the legal actions of the Client.

Quantum Pulse Systems s.r.o. reserves the right to refuse the Client further service and take the appropriate actions described above, after which it transfers all the Client data available , as well as all available information about the Client's operations to law enforcement agencies in the following cases:
- Identification of operations whose purpose is money laundering, financing of terrorist organizations, fraud of any kind.
- Identification of unreliable or fake documents provided by the Client.

Identification of u Policy Review
The policy is subject to updates and amendments, which will be communicated to the stakeholder immediately. Reliable or fake documents provided by the Client.         
Approved for 2023.