Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy

Last updated: July 1, 2025

1. Introduction

At Veli UAB (“Veli”, “we”, or “the Company”), we are committed to maintaining the integrity of the financial system and protecting our platform from being used for money laundering, terrorist financing, or any other unlawful activity.

This policy outlines how we comply with applicable Lithuanian and European Union AML/CTF regulations, including:

  • The Law on the Prevention of Money Laundering and Terrorist Financing,
  • The Law on the Implementation of Economic and Other International Sanctions,
  • The EU AML Directives, MiCA Regulation, and
  • Guidance from the Financial Crime Investigation Service (FCIS), European Banking Authority (EBA), and Financial Action Task Force (FATF).

 

Our framework is built on transparency, proportionality, and risk awareness, ensuring that both Veli and its customers operate within a secure and trusted environment.

2. Purpose and Objectives

The purpose of this policy is to establish clear principles and procedures to prevent the misuse of Veli’s products and services for financial crime.

Our objectives are to:

  • Detect and deter money laundering, terrorist financing, and sanctions evasion;
  • Ensure full compliance with AML/CTF laws and best practices;
  • Maintain transparent customer relationships through strong verification and monitoring; and
  • Protect our users, partners, and the broader crypto ecosystem from financial and reputational harm.

 

Veli takes a zero-tolerance approach to financial crime and expects the same commitment from all customers and business partners.

3. Risk-Based Approach and Risk Appetite

Veli applies a risk-based approach (RBA) to ensure that AML/CTF measures are proportionate to the risks identified.

Each customer, transaction, and service is assessed based on factors such as geography, activity type, transaction volume, and source of funds.

We prioritize controls where the risk is highest and streamline measures for lower-risk cases.

Our risk appetite reflects the following principles:

  • We do not tolerate activity that facilitates money laundering, terrorist financing, or sanctions evasion.
  • We reject or terminate relationships that exceed our internal risk tolerance.
  • We maintain enhanced oversight for politically exposed persons (PEPs), high-risk industries, and transactions involving complex ownership structures.

4. Customer Onboarding Process

Veli’s onboarding process ensures that every customer is properly identified, verified, and risk-assessed before gaining access to our services.

We combine regulatory compliance with customer experience by applying secure, efficient, and privacy-compliant onboarding procedures.

 

4.1 Account Registration

Customers begin by registering on our platform using a valid email address and creating a secure password.

Basic identity details (name, date of birth, nationality, and residence) are collected to initiate verification.

Access to trading, deposits, or withdrawals is restricted until verification is successfully completed.

 

4.2 Identity Verification (KYC)

Individual customers must upload a valid, government-issued ID (passport, national ID, or residence permit) and a recent proof of address.

Corporate customers must provide incorporation documents, company registry extracts, and identification of directors and beneficial owners.

Verification is performed through regulated electronic identification systems and independent data sources, in compliance with Lithuanian and EU standards.

 

4.3 Risk Assessment and Screening

During onboarding, each customer is automatically screened against international sanctions, PEP, and adverse-media databases.

A preliminary risk rating (low, medium, or high) is assigned based on the customer’s profile, jurisdiction, and intended activity.

High-risk cases are escalated to compliance specialists for manual review and, if necessary, Enhanced Due Diligence (EDD).

 

4.4 Source of Funds and Purpose

Customers may be asked to explain the source of their funds or wealth and the intended use of our services.

Supporting documents such as income statements, payslips, or company financials may be required in certain cases.

 

4.5 Approval and Activation

Once verification and screening are complete, the MLRO or compliance team approves the customer’s onboarding.

Verified customers receive full access to the platform.

Ongoing monitoring begins immediately and continues throughout the customer relationship.

 

4.6 Re-Verification and Updates

Veli may periodically request updated information to ensure records remain accurate.

Customers are required to cooperate with any re-verification or review requests to maintain account access.

5. Customer Identification and Verification (KYC/CDD)

Accurate identification is the cornerstone of AML/CTF compliance.

Veli conducts Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures for all users — both individuals and legal entities — before granting access to its services.

5.1 Know Your Customer (KYC)

Before onboarding, every customer must complete KYC verification by providing:

  • Valid government-issued identification;
  • Proof of residential address; and
  • For legal entities: company registration certificates, beneficial ownership details, and evidence of lawful operation.

 

Verification is carried out using secure and regulated electronic tools, ensuring reliability and protection of personal data.

 

5.2 Beneficial Ownership Identification

For companies and organizations, Veli identifies and verifies the Ultimate Beneficial Owners (UBOs) — the individuals who ultimately control or benefit from the entity.

We use official Lithuanian registers and reputable data sources to confirm ownership transparency.

 

5.3 Enhanced Due Diligence (EDD)

When higher risks are identified, Enhanced Due Diligence is applied.

EDD includes obtaining detailed documentation on the customer’s source of funds and wealth, performing independent checks, and obtaining senior management approval before onboarding or continuing the relationship.

EDD is mandatory for:

  • PEPs and their close associates;
  • Customers from high-risk jurisdictions;
  • Large or complex transactions inconsistent with the customer’s profile;
  • Use of privacy-enhancing tools or unregulated exchanges.

 

5.4 Ongoing Monitoring

Once a customer relationship is active, Veli monitors transactions in real time and periodically reassesses risk profiles to ensure consistency with the customer’s declared activity.

6. Detection, Reporting, and Record Keeping

6.1 Suspicious Activity Detection and Reporting

Veli employs automated systems and manual oversight to detect irregular or suspicious transactions.

When potential ML/TF activity is identified, it is reviewed by the Money Laundering Reporting Officer (MLRO) and reported to the Financial Crime Investigation Service (FCIS), if appropriate.

 

6.2 Record Keeping

All verification, transaction, and monitoring data are securely retained for at least 8 years after the end of the business relationship.

Data is stored in accordance with Lithuanian law and the General Data Protection Regulation (GDPR), accessible only to authorized personnel.

7. Restricted and Prohibited Customers

Veli does not engage with:

  • Anonymous or unverified individuals;
  • Sanctioned persons or entities;
  • Shell banks, bearer share companies, or opaque structures;
  • Customers involved in, or suspected of, financial or organized crime;
  • Users employing anonymity-enhancing tools to obscure fund origins;
  • Businesses that cannot demonstrate legitimate economic purpose or ownership.

8. Prohibited Industries and Activities

Veli refuses to provide services to customers or entities involved in:

  • Adult or pornographic content and services;
  • Gambling or betting operations (licensed or unlicensed);
  • Weapons, firearms, or defense-related industries;
  • Narcotics, drugs, or controlled substances;
  • Human trafficking or forced labor;
  • Illegal wildlife trade or exploitation of endangered species;
  • Counterfeit or pirated goods;
  • Multi-level marketing, Ponzi, or pyramid schemes;
  • Unlicensed financial or remittance services;
  • Darknet or anonymity-enhanced crypto activity;
  • Sale of stolen property or data;
  • Shell companies or bearer share corporations;
  • Unlicensed pharmaceuticals;
  • Trade in radioactive, toxic, or dual-use materials;
  • Petroleum or scrap trade without traceable origin;
  • Activities that violate privacy, intellectual property, or human rights.

 

Accounts found to be linked to prohibited industries or activities will be terminated immediately.

9. Sanctions Compliance

Veli complies with all sanctions imposed by the:

  • United Nations (UN),
  • European Union (EU),
  • United States (OFAC), and
  • United Kingdom (HMT).

 

All customers, beneficial owners, and transactions are screened against these lists both during onboarding and continuously.

If a match is found, the account is frozen, and the case is reported to the relevant authority.

10. Employee Training and Awareness

All employees undergo AML/CTF training upon joining and at least once a year thereafter.

Training covers:

  • AML/CTF legislation and internal procedures;
  • How to identify and report suspicious activity;
  • Data protection and confidentiality;
  • Emerging threats and typologies in the crypto sector.

 

Effectiveness is evaluated through assessments and refresher sessions.

11. Independent Review and Continuous Improvement

Veli’s AML/CTF systems are reviewed through regular internal audits and independent evaluations to ensure their effectiveness and regulatory compliance.

Feedback from these reviews, as well as updates in law or market risk, are promptly implemented to keep controls current and robust.

12. Customer Responsibilities

Customers are required to:

  • Provide accurate and up-to-date information;
  • Cooperate with verification and monitoring processes;
  • Use the platform for lawful purposes only; and
  • Notify Veli of any material changes in ownership or personal information.

 

Non-compliance may result in suspension or termination of services.

13. Commitment to Transparency

Veli’s AML/CTF framework promotes transparency, integrity, and trust.

We are committed to continuous improvement and maintaining the highest standards of ethical conduct to protect our customers and the broader financial ecosystem.

14. Contact Information

For any inquiries regarding this AML/CTF Policy, please contact our Compliance Team:

compliance@veli.io