AML/KYC Policy

Purpose of the Policy

The purpose of the AML/CTF policy of Cloudpeak Systems s.r.o. is to prevent the use of the company’s services for money laundering, terrorist financing, and other illegal activities. We aim to ensure full compliance with the laws of the Czech Republic, the European Union, and international standards, as well as to protect the company’s reputation and the trust of our clients.
To achieve this goal, we implement strict procedures for customer verification, transaction monitoring, and risk management, as well as provide employee training and conduct regular audits.

1. User Identification

Cloudpeak Systems s.r.o. conducts mandatory customer identification (KYC) for all clients before establishing business relationships. We use modern technologies to verify the authenticity of documents and identify individuals.
For individuals, the verification process includes providing official identification documents and confirming their authenticity.
For legal entities, we conduct a more stringent verification process, including identifying the ultimate beneficial owner, the company’s structure, and the nature of its business.

If the provided information raises doubts, we may request additional documents or clarifications. If the customer’s identity cannot be verified, services will not be provided.

2. Transaction Monitoring

Cloudpeak Systems s.r.o. continuously monitors all transactions to identify suspicious or unusual activities.
We use automated systems and manual analysis to review transactions, paying special attention to:

• The use of cryptocurrency wallets with a high-risk profile.
• Attempts to conceal the origin of funds through complex transaction schemes.
• Transactions that do not match the customer’s profile.

Suspicious transactions are escalated to AML specialists for further analysis and decision-making.

3. Enhanced Verification

For customers who pose a higher risk, Cloudpeak Systems s.r.o. applies additional verification measures.
This may include:

• Requesting additional documents to confirm identity or address.
• Conducting an in-depth analysis of the source of funds.
• Continuous monitoring of the customer’s activity.

If the provided information does not resolve the doubts, the company reserves the right to terminate the relationship with the customer.

4. Key AML/CTF Rules

Cloudpeak Systems s.r.o. adheres to the following principles:

• We do not accept cash payments or payments via bank cards.
• All transactions are conducted exclusively via bank transfers.
• We do not provide services to customers from countries under international sanctions.
• We do not work with anonymous cryptocurrencies, such as Monero or Zcash.
• We reserve the right to refuse to process a transaction if it poses an AML/CTF risk.

5. Sanctioned Countries

Cloudpeak Systems s.r.o. strictly complies with international sanctions lists, including those of the UN, EU, OFAC, and OFSI.
We do not provide services to citizens, residents, or individuals located in countries that:

• Are under international sanctions.
• Have high levels of corruption or weak anti-money laundering systems.

List of prohibited countries:
Abkhazia, Afghanistan, American Samoa, Akrotiri and Dhekelia, Antarctica, Artsakh, Barbados, Belarus, Botswana, Burkina Faso, Burundi, Cambodia, Cameroon, Central African Republic, Cuba, Democratic Republic of Congo, Crimea Region (Ukraine), Eastern Ukraine, Ethiopia, Haiti, Hawaii, Heard Island and McDonald Islands, Fiji, Guam, Iran, Iraq, Kosovo, Lebanon, Libya, Mali, Mozambique, Myanmar, Nicaragua, Nigeria, North Korea, Pakistan, Palau, Palestinian Territories, Russia, Samoa, Senegal, Somalia, South Ossetia, South Sudan, Syria, Transnistria, Trinidad and Tobago, US Minor Outlying Islands, US Virgin Islands, United States, Uganda, Venezuela, Western Sahara, Yemen, Zimbabwe.

The list of countries is regularly updated in accordance with FATF recommendations and other international organizations.

6. KYC Verification Levels

Cloudpeak Systems s.r.o. uses a multi-level customer verification system. The higher the risk level, the stricter the verification measures applied.
For low-risk customers, standard KYC procedures are applied. For high-risk customers, additional checks are conducted, including in-depth analysis of transactions and the source of funds.

We regularly review KYC procedures to ensure they comply with current legal requirements and best practices.