AML Policy 

LLC "COINMANIA" to promote the prevention of illegal revenue legalization, and for the purposes of preventing and combating terrorismmonitors the following transactions: 

1. For the purposes of this Law, a transaction entered into or conducted by a person and/or a set of transactions entered into or conducted for the purpose of dividing a transaction (transaction amount) (except for transactions conducted through commercial banks, brokerage and insurance companies, lawyers and persons carrying out accounting and/or audit activities, as well as activities subject to monitoring by the Revenue Service) shall 

1.1 The amount of the transaction or of the set of transactions exceeds GEL 30 000 (or its equivalent in another currency), both in the case of cash and non-cash settlements; 

1.2 The agreement is a suspicious, (regardless of its amount and operation), on which there is a reasonable doubt that he has been made or executed for the porpoise of legalization of the illegal income. Or, property (including cash funds) based on which the transaction was signed or executed, is derived or originated from criminal activities, or/and the agreement was signed or executed for the reason of financing terrorism; 

1.3 The client wants to make local and / or international money transfers, which is higher than the 30 000 GEL (or its equivalent in another currency), 

1.4. The suspicion appears to be accurate or in compliance with the client's existing identification data; 

1.5. The transaction is in its essence, in particular: 

1.5.1 Transfer of funds by the account holder from the bank operating or registered in watch or suspicious zone to the bank account in Georgia or transfer of funds from Georgia to account in the bank operating or registered in such zone; 

1.5.2 Transactions implemented in securities by a person present and registered in the watch or suspicious zone (including by a branch of such a legal entity, which is registered in Georgia) and/or through the use of a bank account operating in such zones; 

1.5.3 Provision or receipt of a loan by a person registered in the watch or suspicious zone(including a branch of such a legal entity registered in Georgia) or implementation of any other transaction (operation) by such a person through a banking institution operating in Georgia; 

1.5.4 a person involved in the transaction is on the list of terrorists or persons supporting terrorism, or / and is likely to be connected with them, or / and funds involved in the transaction may be related with or used for terrorism, terrorist act or by terrorists or terrorist organization or persons financing terrorism, or any involved person’s legal or real address or place of residence is located in a non-cooperative zone or the transaction amount is transferred to or from such zone; 

2. Monitoring procedure:

2.1 If the amount of the transaction or of the set of transactions exceeds GEL 30 000 (or its equivalent in another currency), both in the case of cash and non-cash settlements, LLC "COINMANIA" will identify the person involved in the transaction, with the identification documents issued by the relevant state bodies (Identity Card, Passport, if there is the Business case - Certificate of registration, Identification of the person authorized to represent it e.g) “COINMANIA” will keep track of stored data. Before the end of the monitoring, LLC "COINMANIA" has the right to suspend the transaction. In case of necessity, LLC "Coonmania" will provide information to the relevant investigative and competent administrative bodies. 

2.2 If the person involved in the transaction is convicted / suspected for financing of illicit income legalization and / or terrorism, or for other economic crimes, LLC. "COINMANIA" will immediately provide information to the relevant investigative and competent administrative bodies.