The AML/CFT Policy of Starbien Sp. z.o.o. is designed to mitigate risks related to money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes. This page summarizes key aspects of our internal framework. For fuller details, please contact our compliance team.

Starbien is required by law to implement procedures that prevent money laundering and terrorist financing. We appoint an Anti-Money Laundering Officer (MLRO / MLRO), maintain clear governance and escalation lines to senior management, keep our policies up to date, train relevant staff, and promptly report suspicions to competent authorities.

1. Fundamental Procedures

Before providing services or executing transactions for a new user, Starbien implements the following controls:

• Customer Due Diligence (CDD): identify the customer and verify identity with reliable, independent documents/data.
• Recordkeeping: retain KYC and transaction records for the statutory period.
• Ongoing Monitoring: detect unusual or suspicious activity, apply alerts, and, where appropriate, escalate to MLRO.
• Internal Reporting: staff must report suspicions promptly to the MLRO; the MLRO decides on regulatory reporting.
• Staff Training: relevant personnel receive initial and periodic AML training.
• Regulatory Liaison: official correspondence from authorities is handled promptly and centrally by the MLRO/Compliance.

All external AML-related requests are routed to the MLRO/Compliance function.

2. Customer Identity Verification (KYC)

Starbien verifies each customer’s identity and, where applicable, beneficial owners and authorized representatives.

KYC normally includes:

• Full legal name, date of birth, nationality.
• Residential address and contact details.
• Valid government-issued ID (e.g., passport, national ID).
• Source of funds / source of wealth evidence when risk-based triggers apply.
• Sanctions / PEP screening and adverse-media checks.

We may use reputable third-party providers to assist with verification, but Starbien remains legally responsible for KYC outcomes. All personal data is processed in accordance with our Privacy Policy, GDPR, and applicable Polish data protection laws (lawful basis: legal obligation and legitimate interests).

3. Ongoing Transaction Oversight

To manage ML/TF risks effectively, Starbien operates continuous monitoring:

• Automated and manual reviews of patterns, value, frequency, counterparties, geographies, and wallet/payment provenance.
• Alerts for activity inconsistent with the customer’s profile or our risk appetite.
• Sanctions and PEP re-screening at appropriate intervals and on trigger events.
• Immediate escalation of suspicious activity to the MLRO for decisioning (including potential regulatory reporting).

Our aim is precision, timeliness, and the protection of our clients and the integrity of the financial system.

4. Risk Analysis (Risk-Based Approach – RBA)

We apply a **Risk-Based Approach (RBA)** to focus resources where risk is higher. Key features:

• Differentiated Due Diligence (CDD) by customer, product/service, delivery channel, and geography.
• Enhanced Due Diligence (EDD) for higher-risk cases (e.g., PEPs, complex structures, high-risk jurisdictions, unusual patterns).
• Periodic reviews of customers and risk ratings; risk triggers prompt re-verification or restrictions.
• Board and MLRO oversight of risk methodology and control effectiveness, with updates as regulations and typologies evolve.

5. Sanctions Compliance

Starbien prohibits relationships or transactions with persons, entities, or countries subject to applicable international sanctions (e.g., EU, UN; and other regimes relevant to cross-border financial restrictions). We:

• Screen customers, beneficial owners, and transactions against current sanctions lists.
• Block, halt, or reject hits and promptly escalate to the MLRO.
• Report to the competent authority where required.

6. Restricted Regions

Starbien operates geoblocking controls to prevent onboarding or transacting with users from high-risk or non-cooperative jurisdictions. See our Geoblocker Policy for full details.

7. Reporting Obligations

When suspicion of money laundering or terrorist financing arises, the MLRO evaluates the facts and, if warranted, submits a **Suspicious Transaction Report (STR)** to the General Inspector of Financial Information (GIIF) in Poland.

Starbien complies strictly with “**tipping off**” prohibitions – we do not disclose to the customer that a report has been made.

8. Training and Awareness

All staff involved in customer-facing, compliance, or transaction-processing roles receive regular training on:

• AML/CFT legal requirements and internal procedures.
• Recognition of red flags and typologies.
• Escalation protocols and confidentiality.
• Sanctions screening and data protection obligations.

9. Record Retention

We retain KYC documentation and transaction records for **at least 5 years** from the end of the business relationship or transaction, as required by Polish AML law. Records are stored securely and made available to authorities upon lawful request.

10. Policy Review and Updates

This AML/CFT Policy is reviewed at least **annually** and updated whenever there are material changes in legislation, regulatory guidance, business model, or identified risks.

11. Contact the MLRO / Compliance

For questions or to report concerns related to AML/CFT compliance, contact:

Starbien Sp. z.o.o.
Email: support@startbien.com
Address: Plac Bankowy 2/1309, 00-095 Warsaw, Poland