Introduction 

Teroxx Worldwide UAB ‘’the Company’’, is committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and sanctions regulations. This document outlines our approach to ensuring compliance with applicable laws and regulations, safeguarding the integrity of our operations, and preventing the misuse of our services for illicit purposes.

Purpose

The purpose of this document is to provide an overview of our AML/CTF, sanctions and KYC compliance program. It reflects our commitment to identifying, mitigating, and managing risks associated with money laundering, terrorism financing, and sanctions violations. This document does not disclose internal or confidential processes but serves as a public statement of our dedication to compliance.

Key Principles of our AML compliance Program

The Company’s AML/CTF and Sanctions program is built on the following foundational pillars, which ensure a comprehensive and effective compliance framework:

1. Governance and Oversight

• Our compliance program is overseen by a dedicated Head of AML / Money Laundering Reporting Officer (hereinafter - MLRO), who is responsible for implementing and maintaining the program.
• The MLRO reports directly to the Management Board, ensuring accountability and alignment with the company’s strategic goals.
• Regular updates and reports are provided to the Management Board to ensure ongoing oversight and support for compliance initiatives.

2. Compliance with Laws and Regulations

• The Company adheres to the AML, CTF, and sanctions laws and regulations in Lithuania and the jurisdictions where it operates.
• Our policies and procedures are regularly reviewed and updated to reflect changes in regulatory requirements and industry best practices.
• We actively engage with regulatory authorities to ensure our compliance program remains robust and effective.

3. Risk-Based Approach

• We adopt a risk-based approach to compliance, focusing resources on areas of higher risk to ensure effective mitigation.
• Risk assessment is conducted periodically to identify and evaluate risks associated with customers, transactions, products, and geographies.
• Enhanced due diligence (EDD) measures are applied to customers who pose higher ML/TF, and transactions to ensure we apply appropriate scrutiny.

4. Customer Due Diligence (CDD)

• Robust KYC procedures are implemented to establish the identity of our customers and understand the nature of their business relationships.
• CDD measures include:
  • Collecting and verifying customer identification documents.
  • Understanding the purpose and intended nature of the business relationship.
  • Identifying beneficial owners and controlling parties, where applicable.
• Ongoing monitoring is conducted to ensure customer activity aligns with their risk profile and declared purpose of the relationship.

5. Sanctions Compliance

• The Company screens customers, transactions, and counterparties against applicable sanctions lists, including those issued by the United Nations, European Union, OFAC (Office of Foreign Assets Control), and other relevant authorities.
• We ensure that no business is conducted with individuals, entities, or countries subject to sanctions, or has relationships with sanctioned parties.
• Our sanctions compliance measures are updated regularly to reflect changes in global sanctions regimes.

6. Transaction Monitoring and Reporting

• Our systems are designed to monitor transactions for unusual or suspicious activity.
• Alerts generated by our monitoring systems are reviewed by trained compliance personnel to determine if further investigation or reporting is required.
• Suspicious Activity Reports (SARs) or equivalent reports are filed with the relevant authorities in accordance with legal requirements.
• We maintain detailed records of all transactions and reports to ensure transparency and accountability.

7. Prohibited Activities and Customers

Teroxx Worldwide UAB strictly prohibits engaging in business relationships or transactions involving the following:

• Customers or beneficial owners who are on sanctions lists (e.g., EU, UN, OFAC).
• Customers who fail or avoid submitting required identification or documentation.
• Customers providing false or incomplete information or concealing the identity of beneficial owners.
• Customers involved in illegal activities or operating in prohibited industries, including:
  • Illegal arms trade.
  • Human trafficking.
  • Drug trafficking.
  • Unlicensed gambling.
  • Unlicensed virtual asset services.
  • Unregulated money service businesses.
  • Shell companies with no economic activity.
  • Terrorist organizations or affiliates.
  • Businesses linked to counterfeit goods, wildlife trafficking, or pyramid/ponzi schemes.
  • Businesses operating in FATF blacklisted jurisdictions or sanctioned countries.
• Transactions linked to unverifiable sources of funds or prohibited activities.

The Company prohibits the offering of its products and services in jurisdictions listed on FATF lists, the EU third-country list, and countries subject to UN and EU sanctions. Additionally, the Company may prohibit the offering of its products and services in countries known for weak anti-money laundering legislation and enforcement based on the Company’s internal risk assessment.

8. Training and Awareness

• All employees of the Company receive regular training on AML, CTF, and sanctions compliance.
• Training programs are tailored to the roles and responsibilities of employees, ensuring they understand their obligations and can identify and report suspicious activity.
• Training is updated periodically to reflect changes in regulations, emerging risks, and industry trends.

9. Independent Review and Audit

• Our AML and KYC program undergoes regular independent reviews and audits to assess its effectiveness and compliance with regulatory requirements.
• Findings from these reviews are used to enhance our program and address any identified gaps or weaknesses.

10. Record-Keeping and Data Protection

• The Company maintains comprehensive records of customer information, transactions, and compliance activities in accordance with legal and regulatory requirements.
• We ensure that all data is stored securely and handled in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
• Records are retained for the required period and are accessible for regulatory inspections or audits.

Commitment of Ethical Practices

The Company is dedicated to conducting business ethically and transparently. We do not tolerate any form of money laundering, terrorism financing, or sanctions violations. Our compliance program is a cornerstone of our commitment to protecting the financial system and supporting global efforts to combat financial crimes.