AML / KYC

1. Our Commitment

Brontesgate UAB is fully committed to the prevention of money laundering (ML), terrorist financing (TF), proliferation financing, and other forms of financial crime. We operate in strict compliance with the EU Anti-Money Laundering Directives (AMLD5/6), the FATF Recommendations, and the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania.

Our mission is to provide a secure, transparent, and compliant fiat-to-crypto exchange service for customers in the European Economic Area (EEA), while ensuring adherence to all legal obligations and maintaining customer trust.

2. Know Your Customer (KYC) / Customer Due Diligence (CDD)

Brontesgate UAB applies full CDD to all customers before providing access to services. Onboarding requires:

• Verification of identity using valid government-issued identification (passport or national ID).
• Collection of proof of address (utility bill, bank statement, or government-issued document).
• Biometric/liveness checks.
• Screening against international sanctions, PEP lists, and adverse media sources.

We use industry-leading third-party providers (e.g., Sumsub) to perform verification efficiently and securely, in compliance with GDPR.

3. Risk-Based Approach

Brontesgate UAB applies a risk-based approach in line with FATF and EU principles. Depending on the customer profile, transaction history, and geographic factors, the Company may:

• Request additional documentation (e.g., source of funds, source of wealth).
• Apply EDD when monthly transactions exceed EUR 25,000 or risk indicators are present (e.g., IP mismatch, age over 70, PEP/adverse media hit, high-risk sector).
• Delay, suspend, or decline transactions if suspicious patterns or compliance concerns arise.

All customers are continuously risk-scored, and risk categories are periodically reviewed.

4. Sanctions and Prohibited Jurisdictions

Brontesgate UAB does not provide services to individuals or entities that are:

• From jurisdictions sanctioned by the EU, UN, OFAC, or Lithuanian authorities.
• Listed by the FATF as high-risk or non-cooperative.
• Considered high-risk under our internal compliance policy (e.g., gambling, adult services, cash-intensive businesses, precious metals/gems trading, MSBs, PSPs, correspondent banks, NPOs).

Only natural persons and legal entities in e-commerce and IT sectors from the EEA will be accepted as customers.

5. Monitoring and Reporting

• Incoming transactions are reviewed manually by the compliance team and monitored through our banking partners' AML systems.
• Outgoing crypto transactions are screened with blockchain analytics tools to identify wallet risk, links to sanctioned addresses, darknet exposure, or other red flags.
• All customer activity is subject to ongoing monitoring.
• Suspicious transactions will be reported to the FNTT without delay, in line with Lithuanian law.

6. Data Protection

All customer data is collected, stored, and processed securely under the General Data Protection Regulation (GDPR) and Lithuanian data protection requirements.

• Data is encrypted and retained for a minimum of five years after the end of the customer relationship or longer if required by law.
• Customers' personal information is only used for compliance, risk management, and legal obligations.

7. Contact Us

For any questions regarding this AML / KYC Policy or to report a concern, please contact our Compliance Team:

📧 Email: aml@brontesgate.com

🏢 Address: Brontesgate UAB, Žalgirio g. 88-101, LT-09303 Vilnius, Lithuania