Anti-Money Laundering (AML) & Sanctions Policy

1. Purpose

This policy sets out how we prevent our company and services from being used for money laundering, terrorist financing, sanctions evasion, fraud, bribery or corruption.

2. Know Your Customer (KYC)

Before entering into a business relationship we verify the identity of every client: company name, registration number, registered address, VAT ID and the identity of the persons authorised to represent it, using official registers (e.g. KRS, Handelsregister, Firmenbuch, VIES).

We identify the ultimate beneficial owners (UBO) holding more than 25% of shares or voting rights, using central beneficial ownership registers (e.g. CRBR, Transparenzregister, WiEReG register) where available.

3. Sanctions screening

Clients, their representatives and beneficial owners are screened against the consolidated EU sanctions lists, the UN Security Council lists, the UK HM Treasury list and the US OFAC SDN list. We do not enter into or continue business relationships with sanctioned persons, entities, or entities in sanctioned jurisdictions, and we comply with the EU restrictive measures against Russia and Belarus.

4. Risk-based approach

Each client is assessed for risk based on country, industry, ownership structure and the nature of the requested services. Enhanced due diligence is applied to politically exposed persons (PEPs), high-risk third countries identified by the European Commission and FATF, and unusual or complex structures.

5. Payments

We accept payments only by bank transfer from a business bank account held in the name of the contracting client. We do not accept cash, cryptocurrencies or payments from third parties. Invoices are issued exclusively to the verified contracting party. Refunds are made only to the account from which the payment originated.

6. Monitoring and reporting

We monitor business relationships for unusual transactions, such as payments inconsistent with the agreed scope, requests to split or redirect payments, or reluctance to provide identification. Where there is a justified suspicion of money laundering or terrorist financing, we will refuse or terminate the relationship and notify the competent authorities, in particular the General Inspector of Financial Information (GIIF) or the public prosecutor.

7. Anti-bribery and corruption

We do not offer, give, request or accept bribes, facilitation payments or improper advantages of any kind. Gifts and hospitality are permitted only in modest amounts and in full transparency.

8. Record keeping

KYC documents, screening results and transaction records are retained for 5 years from the end of the business relationship, in accordance with the GDPR and applicable law, and protected against unauthorised access.

9. Training and responsibility

The Management Board is responsible for this policy and appoints a person responsible for compliance. All employees and contractors are informed of the policy and receive regular training.

10. Client cooperation

By entering into a business relationship with us, clients agree to provide the information and documents required for these checks. We may suspend services until verification is complete.

11. Contact

Compliance questions and reports: office@rs-code.com, +48 571 268 881, RS-CODE Sp. z o.o., ul. Długa 46/13, 47-400 Racibórz, Poland.