KYC & AML POLICY


version 1.03

dated on 1 July 2024 



Paradox Labs Inc is a company specializing in facilitating trading activities for
clients within the platform of Binance crypto exchange and Bybit crypto exchange.
Registered in accordance with the laws of the Republic of Panama, Paradox Labs
Inc operates solely from its registered headquarters and does not maintain any
branches elsewhere.
The company has developed a comprehensive KYC & Anti-Money Laundering
Policy and Combating Financing of Terrorism Policy (hereafter referred to as the
AML Policy) to actively mitigate the risks associated with money laundering and
the facilitation of illicit financial activities, including terrorism financing and tax
evasion. Money laundering encompasses activities aimed at concealing or
disguising the origins of unlawfully obtained funds to make them appear legitimate.
This policy outlines detailed procedures and obligations to ensure compliance with
Know Your Client (KYC) norms, Anti-Money Laundering (AML) regulations,
Client Due Diligence (CDD) requirements, and measures for Combating the
Financing of Terrorism (CFT).





1. KEY DEFINITIONS

Act – LAW 23 of 27 April 2015 - Adopting Measures for the Prevention of Money
Laundering, Terrorism Financing and Financing of Proliferation of Weapons of
Mass Destruction and other provisions (Republic of Panama);
MLRO – Money Laundering Reporting Officer - a person responsible for ongoing
AML activities in Paradox Labs Inc;
Client's Account – means sub-account, which is open by Paradox Labs Inc to the
client as a part of Paradox Labs Inc account with Binance crypto trade ecosystem
for trade purposes;
FATF – Financial Action Task Force, the inter-governmental body which sets
international standards that aim to prevent these illegal activities and the harm they
cause to society;
FIU – Financial intelligence unit of Panama (https://www.uaf.gob.pa/);
STR – Suspicious Transaction Report;
ML/TF – Money laundering/terrorist financing.

2. KYC PROCEDURES
Paradox Labs Inc provides access to its services contingent upon the completion
of a Know Your Customer (KYC) procedure by the client.
The KYC process is of paramount importance in the operations of Paradox Labs
Inc. The company exclusively accepts clients who are natural persons aged 18
years or older.
Paradox Labs Inc does not accept:
- Legal entities,
- Funds,
- State bodies.
Information about a client to be collected include:
- Full name;
- Date of birth;
- Nationality;
- Identity document type and number;
- Residential address.
Paradox Labs Inc should obtain a valid travel document - passport or a relevant
national identity card (issued by government) bearing the person’s photograph;
or
A valid national driving license (issued by government) bearing the person’s
photograph.
Copies of the aforementioned documents are retained throughout the duration of
the customer relationship and for a period of 5 years following the termination of
said relationship.
To authenticate the validity of the provided documents, Paradox Labs Inc reserves
the right to request a selfie from prospective clients, which must be submitted
through the company's website. The individual should be depicted without glasses
or headwear.
Politically exposed persons (PEP)
According to the Financial Action Task Force (FATF), a politically exposed person
(PEP) is an individual who currently holds or has previously held a significant public
office. Given their authority and influence, it is acknowledged that PEPs often
occupy positions vulnerable to exploitation for money laundering (ML) activities
and associated predicate offenses, such as corruption, bribery, and involvement in
terrorist financing activities.


Paradox Labs Inc prohibits the acceptance of politically exposed persons (PEPs)
as clients. Should an existing client attain PEP status, Paradox Labs Inc reserves
the right to terminate the client relationship with a 30-day prior notice.
In the event that a person identified as a PEP is inadvertently accepted as a client,
Paradox Labs Inc retains the authority to promptly terminate the relationship, close
any active orders, and return all funds to the client.
Exceptions may be considered for maintaining relations with former PEPs,
provided they have retired from public office or ceased all political activities.

FATF "Call for action" list
Paradox Labs Inc does not establish or maintain business relations with citizens/
residents of FATF "Call for action" list countries:
- Iran
- Democratic People's Republic of Korea (DPRK).
In case FATF revises its list, Paradox Labs Inc acts accordingly.
As far as Binance does not accept clients from:
- Canada
- Netherlands
- United States
- Syria
- Crimea, Donetsk and Lugansk areas.
Paradox Labs Inc does not accept clients from these jurisdictions either.
Paradox Labs Inc hereby notifies its clients that while temporarily located within
the aforementioned countries, they are not authorized to conduct any inflow or
outflow transactions on their accounts.
Paradox Labs Inc divides the clients into groups depending on the level of risk:
- high-risk clients,
- standard risk clients.
High-risk clients are:
Those, who are citizens/residents of "jurisdictions with strategic deficiencies" and
"high-risk third countries».
Paradox Labs Inc relies upon FATF and European Commission in definition of the
countries which has deficiencies in AML.
High-risk jurisdictions for which EDD apply include the countries from the lists of
FATF "Jurisdictions with strategic deficiencies" and European Commission "High-
risk third countries»

Jurisdictions with strategic deficiencies:

- Bulgaria
- Burkina Faso
- Cameroon
- Democratic Republic of Congo
- Croatia
- Haiti
- Jamaica
- Kenia
- Mali
- Mozambique
- Namibia
- Nigeria
- Philippines
- Senegal
- South Africa
- South Sudan
- Syria
- Tanzania
- Turkey
- Yemen
- Vietnam
High-risk third countries:
- Afghanistan
- Barbados
- Burkina Faso
- Cameroon
- Democratic Republic of Congo
- Hibraltar
- Haiti
- Jamaica
- Mali
- Mozambique
- Myanmar
- Nigeria
- Panama
- Philippines
- Senegal
- South Africa
- South Sudan
- Syria
- Tanzania
- Trinidad and Tobago
- Uganda
- UAE
- Vanuatu
- Vietnam

- Yemen
Given the insufficient level of anti-money laundering measures in these countries,
the Money Laundering Reporting Officer (MLRO) reserves the right, at their
discretion, to request evidence substantiating the origin of funds. Such evidence
may include salary statements, dividend transfers, proceeds from asset sales, and
other relevant documentation.

3. CUSTOMER DUE DILIGENCE
Customer due diligence (CDD) aims to facilitate the Company in establishing a
reasonable assurance regarding the accurate identification of each customer,
ensuring a high level of confidence in their true identity.
Types of CDD
Standard CDD
A standard level of Customer Due Diligence (CDD) is typically applied uniformly to
all customers who receive specified services and are personally met by the service
provider.
Given that the majority of clients establish relations without face-to-face meetings
with the management team of Paradox Labs Inc, Enhanced CDD procedures are
required.
Enhanced CDD
An increased level of CDD for those clients that are reasonably determined by to
be of higher risk due to the country of residence.
Ongoing DD
MLRO officer carries out ongoing due diligence as per the following schedule:
a) Standard risk clients - Once a year - MLRO might demand to present the
confirmation of the place of residence checks;
b) High risk clients - Once every 6 months - MLRO checks if the clients are on
sanction lists;
c) Clients, residents from Russia and Belorussia, - Once every 6 months - MLRO
checks if the clients are on sanction lists.


All the clients are checked whether they became PEPs on annual basis. Paradox
Labs Inc conducts reviews of customer records in response to specific triggering
events, such as:

- Significant transactions, defined by monetary value or if the transaction is
unusual or diverges from the customer's typical activity;

- Instances where Paradox Labs Inc identifies insufficient information regarding
the respective customer.

4. SANCTIONS POLICY
Paradox Labs Inc acknowledges and adheres to sanctions imposed by the
European Union, United Nations Organization, and the United States Department
of the Treasury's Office of Foreign Assets Control (OFAC).
The company is dedicated to strict compliance with all relevant sanctions
governing its business operations. Paradox Labs Inc abstains from participating in
transactions or activities intended to evade or facilitate the violation of applicable
sanctions.
Exceptions to these stringent standards are permissible only under extraordinary
circumstances, subject to prior authorization from senior management and in strict
accordance with applicable laws.
To effectively manage exposure to sanctions risks and ensure adherence to
regulatory requirements, Paradox Labs Inc employs robust controls and
processes, including thorough screening and due diligence procedures on
counterparties.
Utilizing a risk-based approach, the company evaluates whether counterparties
pose a sanctions risk or are potential targets of sanctions.
Employees are required to maintain vigilance regarding sanctions risks and
promptly report any identified sanctions-related issues to compliance authorities.
Paradox Labs Inc rigorously enforces its policy of not engaging with individuals
listed on sanction lists maintained by the European Union and the United Nations.



The Money Laundering Reporting Officer (MLRO) routinely reviews clients from
Russia and Belarus every six months. Should any client be found on sanctions lists
during these reviews, the MLRO promptly notifies management, and Paradox Labs
Inc terminates business relations with the affected clients, returning their funds
accordingly.
Paradox Labs Inc uses Binance official KYC system (Binance SumSub and wck) as
a service for PEP identification process.

5. REPORTING SUSPICIOUS TRANSACTIONS
When Paradox Labs Inc identifies or suspects that a transaction is linked to money
laundering (ML) or terrorist financing (TF) activity, it employs the "SAFE" approach
as advocated by the Financial Intelligence Unit (FIU) to mitigate associated risks.
The "SAFE" approach entails four key steps:
- Screen the account for suspicious indicators;
- Ask the customers appropriate questions;
- Find out the customer’s records;
- Evaluate all the above information.
When Paradox Labs Inc becomes aware of or suspects that specific assets
constitute proceeds of criminal activity or terrorist financing, it is obligated to
promptly disclose this information to the Financial Intelligence Unit (FIU) within a
reasonable timeframe.
Suspicious Transaction Reports (STRs) must be submitted to the FIU prior to
Paradox Labs Inc engaging in any suspicious transaction or activity on behalf of its
clients. In cases where the suspicion arises subsequent to the completion of a
transaction or activity, the STR should be filed with the FIU as soon as feasibly
possible.
Internal reporting
Paradox Labs Inc implements ongoing measures to systematically evaluate and
maintain appropriate policies and procedures, ensuring adherence to legal and
regulatory mandates. The selection and scope of these measures are tailored to
the company's risk exposure to money laundering (ML) and terrorist financing (TF),
as well as the scale of its operations.
The Money Laundering Reporting Officer (MLRO) serves as the central focal point
for reporting suspicious transactions within Paradox Labs Inc. The company
ensures that the MLRO holds a prominent position within the organizational
structure and is provided with adequate resources to fulfill their duties effectively.
One of the primary responsibilities of the MLRO is to meticulously assess all
pertinent information and promptly report any suspicious transactions, activities, or
attempted transactions to the Financial Intelligence Unit (FIU) in accordance with
statutory obligations.

6. EMPLOYEE TRAINING



Ensuring staff proficiency is paramount in combatting money laundering and
terrorist financing. It is imperative to demonstrate that all personnel are well-versed
in relevant laws and understand their individual responsibilities.

Documentation of training should encompass attendance logs, staff
acknowledgment of legal/regulatory awareness, retention of training materials,
records of orientation sessions for new hires to familiarize them with internal
protocols and anti-money laundering (AML) legislation.
Informal training sessions, commonly conducted on-the-job, are prevalent among
professionals in AML/counter-terrorist financing (CTF) efforts, often lacking formal
documentation.
While on-the-job training suffices for most staff, the Money Laundering Reporting
Officer (MLRO) necessitates formal training.
Primary areas of employee training encompass:
(a) Statutory obligations pertinent to Paradox Labs Inc;
(b) Potential ramifications of breaching these obligations;
(c) Paradox Labs Inc's protocols and procedures regarding Anti-Money Laundering
(AML) and Counter-Terrorist Financing (CTF), notably in the context of identifying
and reporting suspicious transactions.
Staff members undergo mandatory annual training on money laundering, with
additional sessions warranted by various circumstances, including:
- Onboarding of new employees;
- Employee transfers or promotions within the organization;
- Legislative changes;
- Alterations in risk levels.
All new hires, regardless of rank, are required to:
a. Familiarize themselves with the AML Policy and relevant legislation;
b. Review Binance's Terms and Conditions.
Subsequently, the MLRO administers queries or assessments to evaluate
comprehension.
The MLRO is obligated to undergo periodic training, irrespective of the venue.
Additionally, MLRO training must encompass cryptocurrency matters, such as
legal frameworks, regulatory requirements, and licensing procedures.

7. RECORD KEEPING
The Company meticulously maintains comprehensive records of customers,
transactions, and other pertinent data necessary to fulfill the record-keeping
obligations mandated by the relevant legislative framework and regulatory
directives.

Throughout the duration of the customer relationship and for a period of 6 months
following the termination thereof, all records pertaining to each customer and
transaction are diligently preserved.
Paradox Labs Inc retains copies of pertinent documents and meticulously logs the
data and information acquired during the process of customer identification and
verification.
Regarding transactions, the Company archives detailed information pertaining to
asset inflows and outflows from client accounts, including:
- Transaction nature and date
- Currency/cryptocurrency type and amount
- Fund origin (if ascertainable)
- Account type and identifying number (if applicable)
- Account access details: time and IP address
This information is securely stored for a minimum duration of six months.
Documents forming part of the record are digitized and stored in the company's
computer database in any feasible format. The same procedure applies to any
information gathered by the Company during the customer identification process.
Format of record-keeping:
- Original documents,
- Photocopies or scans of original documents
Computerized or electronic form records



Format of computer files:
- PDF - for scanned copies (BMP, JPEG possible);
- WORD/EXCEL - for information.
Where the documents are kept:
- Originals - where the management body resides;
- Electronic documents, records, and scanned copies are utilized at the discretion

of the Money Laundering Reporting Officer (MLRO) within Paradox Labs Inc.

A backup copy of electronic documents is generated every three months to ensure
data integrity and availability.


The MLRO oversees document access within the company, permitting access
exclusively to authorized staff members while implementing measures to mitigate
the risk of unauthorized data breaches.