Anti-Money Laundering Policy

1. Introduction and Purpose

STELLAR is committed to maintaining the highest standards of anti-money laundering (AML) compliance. This policy outlines our procedures to prevent, detect, and report money laundering activities and terrorist financing.

This AML Policy applies to all users, employees, and partners of STELLAR. We are dedicated to operating in compliance with applicable anti-money laundering laws and regulations in Poland and the European Union.

2. Regulatory Framework

Our AML program is designed to comply with:

• Polish Act on Counteracting Money Laundering and Terrorism Financing (AML/CFT Act)
• Financial Action Task Force (FATF) recommendations
• International sanctions regulations
• Applicable EU anti-money laundering directives where relevant

3. Know Your Customer (KYC) Procedures

Customer Identification

All users must complete our verification process before accessing certain platform features. We collect and verify the following information:

• Full legal name
• Date of birth
• Residential address
• Government-issued identification document
• Proof of address (where required)

Enhanced Due Diligence

Enhanced due diligence is applied in higher-risk situations, including:

• High-value transactions or account activity
• Users from high-risk jurisdictions
• Politically exposed persons (PEPs)
• Complex or unusual transaction patterns

4. Transaction Monitoring

Ongoing Monitoring

We continuously monitor transactions on our platform for suspicious activity. Our monitoring systems track:

• Transaction volumes and patterns
• Credit purchase behavior
• Geographic indicators
• Account activity anomalies

Red Flags

We actively monitor for indicators of suspicious activity, including but not limited to:

• Unusually large or frequent credit purchases
• Rapid movement of credits between accounts
• Transactions with no apparent business purpose
• Attempts to avoid identification requirements
• Use of multiple accounts or payment methods

5. Sanctions Screening

STELLAR screens all users against applicable sanctions lists, including:

• United Nations Security Council sanctions lists
• OFAC Specially Designated Nationals (SDN) list
• EU consolidated sanctions list
• Polish and EU national sanctions lists

Users found on sanctions lists will be denied access to the platform, and existing accounts will be suspended pending investigation.

6. Record Keeping

We maintain comprehensive records of all customer identification information and transactions for at least five (5) years after the end of the business relationship or the date of the transaction, whichever is later. Records include:

• Customer identification and verification documents
• Transaction records and account statements
• Correspondence related to suspicious activity
• Internal investigation reports
• Training records for employees

7. Suspicious Activity Reporting

Internal Reporting

All employees and users are encouraged to report any suspicious activity to our compliance team immediately. Reports should be made to compliance@stellarai.space.

Regulatory Reporting

When required by law, we file Suspicious Activity Reports (SARs) with the appropriate regulatory authorities. We cooperate fully with law enforcement investigations.

Confidentiality

All suspicious activity reports are treated as strictly confidential. We do not inform the subject of a report that a SAR has been filed (tipping off is prohibited by law).

8. User Obligations

By using STELLAR, you agree to:

• Provide accurate and complete identification information
• Update your information promptly if it changes
• Not use the platform for money laundering or terrorist financing
• Not circumvent our verification or monitoring procedures
• Cooperate with our compliance team when requested
• Report any suspicious activity you observe on the platform

9. Account Restrictions and Termination

STELLAR reserves the right to:

• Refuse to open an account or process a transaction
• Suspend or freeze accounts pending investigation
• Close accounts where suspicious activity is confirmed
• Report users to appropriate authorities
• Withhold funds subject to legal proceedings

These actions may be taken without prior notice where permitted by law.

10. Training and Awareness

All STELLAR employees receive regular training on:

• Identifying suspicious activity
• Customer due diligence requirements
• Record-keeping obligations
• Reporting procedures
• Current money laundering methods and trends

11. Policy Updates

This AML Policy is reviewed and updated regularly to reflect changes in regulations, industry best practices, and our business operations. We will notify users of material changes through our platform or via email.