AML/CFT Policy

Last Updated: 17 Mar 2025

1. Our Commitment: Combating Financial Crime

At Solarbee.io, we are dedicated to preventing money laundering (ML) and terrorist financing (TF) to safeguard the integrity of the digital asset ecosystem. We recognize that these illicit activities erode trust, fuel corruption, and harm legitimate users. This policy, alongside our Terms and Conditions and other relevant documents, outlines the robust measures we implement to prevent criminals from exploiting Solarbee.io. Our aim isn't just to meet legal obligations, but to proactively minimize risks and uphold the highest standards in anti-money laundering and counter-terrorist financing. As a global platform, Solarbee.io adheres to the laws and legal requirements enforced by the authorities in Poland, the jurisdiction governing these rules.

2. Who This Policy Applies To

This policy applies to all customers engaging in transactions on the Solarbee.io website and its associated mobile application (collectively, "the Platform"). Customers are expected to comply with the AML/CFT laws and regulations of their respective countries or regions. If your local requirements are stricter than those outlined here, the stricter requirements will apply. This policy is governed by and construed in accordance with the laws of Poland.

3. Understanding Money Laundering and Terrorist Financing

Our fight against ML/TF targets activities where illicit funds - derived from crimes such as narcotics trafficking, organized crime, terrorism, smuggling, corruption, bribery, financial fraud, and breaches of financial regulations - are disguised or concealed through the Platform.

4. Our AML Framework

Solarbee.io's comprehensive AML/CFT framework includes this policy, relevant sections within the Solarbee.io Terms and Conditions, our KYC Policy, and our internal policies and procedures. In case of any conflict, this policy generally takes precedence over the Terms and Conditions. However, specific measures and guidelines for large-sum transactions and OTC activities will prevail over this policy.

5. Core AML Principles

Solarbee.io applies the following fundamental principles to effectively monitor customer risks:

Comprehensiveness: We consider all potential risk factors associated with money laundering to monitor all customers appropriately.
Prudence: We strive for a deep understanding of our customers, continuously enhancing our identity authentication capabilities and carefully monitoring risks.
Sustainability: We maintain ongoing vigilance regarding customer risks and adapt our responses based on the specific circumstances of each risk.
Confidentiality: All customer identity and transaction information, as well as risk levels, are kept strictly confidential. This information will only be disclosed when legally mandated or requested by regulatory authorities.
Hierarchical Management: We regularly review customer information based on their assigned risk levels, with higher-risk customers undergoing more rigorous scrutiny.

6. AML Organizational Structure

Solarbee.io's AML operations are managed by a dedicated guidance group for money laundering affairs and a team for advancing the fight against money laundering. Both comprise members from our risk control and compliance departments.

7. Responsibilities of AML Organs

The guidance group is responsible for strategic planning, guidance, and coordination of AML efforts, including:

Reviewing and approving AML policies, plans, and reports.
Issuing and updating AML guidelines and rules.
Reviewing the Platform's AML organizational structure and responsibilities.
Designing and improving internal transaction inspection and control procedures.
Addressing complex AML challenges and formulating solutions.

The team for advancing the fight against money laundering executes these strategies and plans, with key responsibilities including:

Implementing AML rules and assignments from the guidance group.
Analyzing and identifying the identity, background, and nature of suspicious transactions and customers.
Assessing and adjusting customer risk levels.
Conducting due diligence and continuous supervision of customers.
Reviewing and regularly examining past transactions.
Reporting suspicious transactions to competent authorities.
Assisting in investigations as requested by authorities.

8. Due Diligence Procedures

Solarbee.io conducts due diligence on all customers, adhering to the principles of diligence and "Know Your Customer" (KYC). For customers identified as high-risk, we reserve the right to perform enhanced due diligence.

9. Required Documents for Individual Customers

To comply with varying jurisdictional requirements, the information collected from individual customers may differ. Generally, individual customers are required to provide:

Full legal name
Residential address
Date of birth
Nationality
Telephone number
Email address
A recent photograph (taken within six months of registration)
A photocopy of a valid Identity Card or passport
Any other information or documents requested by Solarbee.io

10. Required Documents for Institutional Customers

Similarly, information for institutional customers may vary by jurisdiction. Typically, institutional customers must provide:

Institution's legal name
Registered office address
Contact information
Articles of association
Description of equity structure and ownership
Legal representative's name
Legal representative's place of residence
Legal representative's contact information
Institution's business license
Institution's consent to open an account with Solarbee.io
Letter of authorization by the institution
A copy of the legal representative's valid Identity Card or passport
Any other information or documents requested by Solarbee.io

11. Language of Submitted Documents

Solarbee.io accepts documents prepared only in Polish and English. Customers submitting documents in other languages must provide a professionally translated and notarized English version.

12. Submission of Document Copies

If submitting document copies, they must be accurately checked against the original and, if necessary, notarized and certified as true and accurate copies. This certification can be from an embassy, judicial authority, local magistrate, or notary public.

13. Photo-based Verification

Customers are required to complete a photo-based verification process. This involves submitting a photograph of themselves holding their identity document and a statement affirming their voluntary account opening with Solarbee.io. Solarbee.io reserves the right to reject registrations if the photograph is unclear or does not meet our requirements.

14. Identification of Beneficial Owners and Controllers

Solarbee.io retains the right to identify the actual or beneficial owner or controller of a customer's account. For institutional customers, any shareholder holding more than 25% of the institution's shares must provide relevant materials and undergo identity verification as required.

15. Third-Party Identity Authentication

Should Solarbee.io or a sub-website entrust a third-party institution with customer identity authentication, that institution must:

Have robust measures for customer identification and information storage, compliant with AML laws and Solarbee.io's policies.
Ensure the seamless and legally unhindered provision of customer information to Solarbee.io.
Enable Solarbee.io to promptly obtain customer information and, if needed, original or certified copies of identity documents from the third party.

16. Review of Customer Documents

Solarbee.io verifies and records customer-submitted information according to our customer identification system. If any doubts arise regarding submitted information, we may request additional documents or consult relevant authorities for verification.

17. Customer Risk Classification

Based on submitted materials and factors such as geographical location, industry involvement, shareholder background (if applicable), and whether customers are prominent public figures, Solarbee.io classifies customers into three categories: low-risk, medium-risk, and high-risk. Solarbee.io reserves the right to adjust these classifications.

18. High-Risk Customer Identification

High-risk customers typically exhibit one or more of the following factors after comprehensive evaluation:

Currently or previously under criminal or administrative investigation (excluding civil or emergency disputes).
Prominent public figures, or whose controlling shareholders, actual controllers, or beneficiaries are prominent public figures.
Originating from high-risk countries or regions, or whose controlling shareholders, actual controllers, or beneficiaries are from such areas.
Identified as key suspicious customers through Solarbee.io's internal procedures.
Engaged in businesses with high money laundering risks (e.g., jewelry, precious metals trading, currency exchange, pawn brokerage, money remittance, nightclubs, arms industry).
Engaging in intensive trading inconsistent with digital asset market conditions.
Exhibiting unusual operational patterns.

19. Low-Risk Customer Identification

Low-risk customers are identified after a comprehensive evaluation and include:

Financial institutions or well-known companies.
Natural persons whose identities are thoroughly understood and verified by Solarbee.io, and who present a low money laundering risk.
Customers reviewed and approved by Solarbee.io's risk control and compliance departments.

20. Medium-Risk Customer Identification

Medium-risk customers are those who do not fall into the high-risk or low-risk categories as defined above.

21. Risk Level Adjustments

Solarbee.io continuously monitors customer identity and transaction status. Any changes, abnormalities, or doubts about customer information will trigger a re-identification of customer identity and a timely adjustment of their risk level. Solarbee.io has the discretion to adjust risk levels without providing reasons.

22. Monitoring of High-Risk Customers

For high-risk customers, Solarbee.io conducts regular reviews to update their identity information and ascertain their funding sources, fund usage, financial standing, or business status. If, after a comprehensive assessment, the customer and their transactions are deemed normal, their risk level may be lowered.

23. Continuous Customer Identification

Throughout the business relationship, Solarbee.io employs continuous customer identity verification to track transaction status. If customer identity information or data expires and is not updated within a reasonable period without justification, Solarbee.io may suspend services for that customer.

24. Re-identification of Customers

Solarbee.io reserves the right to re-identify a customer's identity under any of the following circumstances:

Customer requests to change name, identity certificate type, ID number, registered capital, business scope, or legal representative.
Abnormal customer conduct or trading patterns.
Customer's name matches that of a criminal suspect, money launderer, or terrorist financier.
Suspicion of money laundering or terrorist financing.
Inconsistencies or contradictions between newly acquired customer information and existing data.
Doubts about the authenticity, validity, or integrity of previously obtained customer information.
Any other circumstances deemed necessary by Solarbee.io for re-identification.

25. Trading Limits

Solarbee.io may set and adjust maximum withdrawal amounts for scheduled transactions at any time, based on transaction security and prevailing conditions.

26. Identification of Suspicious Transactions

Solarbee.io has the right to verify the following suspicious transactions and accounts:

Dispersed digital asset transfers are followed by collective transfers out, or vice-versa, within a short period, inconsistent with the customer's identity, financial standing, or business operations.
Sudden reactivation of a long-inactive account, or a sudden large inflow of digital assets into an account with typically small flows, followed by a large withdrawal within a short period.
Opening or cancellation of a large number of accounts without justification, especially with large deposits or withdrawals before cancellation.
Suspicious lump-sum deposits or withdrawals in a natural person's account.
Excessively frequent trading within a certain period, significantly inconsistent with digital asset market conditions.
Other suspicious trading situations identified by Solarbee.io.

27. Identification of Terrorist Financing

If Solarbee.io suspects that a customer's transaction or attempted transaction is linked to terrorism, terrorist crime, a terrorist organization, or individuals involved in terrorist financing, appropriate measures will be taken regardless of the fund amount or asset value.

28. Handling Suspicious Conduct

When suspicious conduct is identified, Solarbee.io reserves the right to take measures such as suspending suspicious transactions, rejecting transaction applications, reversing transactions, freezing suspicious accounts, and reporting to competent authorities if a customer:

Refuses to provide valid identity or other identification documents.
Refuses to update their profile without justifiable reason.
Leaves Solarbee.io with doubts about the authenticity, validity, or integrity of their identity information after necessary measures are adopted.
Forges or alters identification documents to deceive Solarbee.io into opening an account.
Refuses to provide a reasonable explanation for suspicious conduct, or their explanation is clearly unjustifiable.

29. Customer Data Storage System

Solarbee.io maintains a robust system for storing customer identity information and transaction records. This ensures proper preservation of documents and data, facilitating money laundering investigations, supervisory oversight, and preventing information loss, damage, or unauthorized disclosure.

30. Scope of Data and Transaction Record Storage

The data saved by Solarbee.io includes customer-provided identity information, records of Solarbee.io's identity verification processes, and details of each transaction, reflecting the actual circumstances of the transactions.

31. Data Retention Periods

Solarbee.io retains customer identity information and transaction records for specific periods:

Customer identity information: At least five years from the date the business relationship between the customer and Solarbee.io ends.
Transaction records: At least five years from the date the transaction is recorded.
Ongoing investigations: If customer identity information or transaction records are involved in a money laundering investigation that extends beyond the minimum storage term, they will be retained until the investigation concludes.

32. Assistance to Judicial Investigations

Solarbee.io will cooperate with judicial, law enforcement, or other competent authorities from any country or region that submits a request for assistance in an investigation, providing relevant information and materials as required.

33. AML Confidentiality

All Solarbee.io staff members who encounter AML-related information through their duties must strictly maintain confidentiality. This includes customer identity information, suspicious transactions, terrorist financing transactions, and any other sensitive data obtained. Such information may not be disclosed to any unauthorized organization, individual, or unrelated staff member.

34. Important Customer Cautions

Customers are advised to adhere to the following:

Do not pass your account details to anyone else.
Do not pass your identity certificates to anyone else.
Do not pass or disclose important personal asset information, such as account details and passwords.
Actively cooperate with Solarbee.io in customer identification processes.

35. Reporting Suspicious Conduct

Customers of Solarbee.io are encouraged to report any accounts they suspect may be engaged in money laundering or terrorist financing activities on the Platform.

36. Policy Interpretation

This policy shall be interpreted by Solarbee.io.