This Policy sets out the framework, the key principles rules and measures designed to protect the Bank and the Group companies against possible use of its products and services for ML/TF purposes via transactions or customers dealing with Virtual Assets.

The Bank adopts appropriate measures to identify, assess and effectively manage the ML/TF risk connected to Virtual Assets, taking into account risk factors, such as those related to the Bank’s customers, business relationships, countries or geographic areas, products, services, transactions or delivery channels, the methods of account opening on a risk-based, proportionate and effective way. The scope of the measures adopted by the Bank are commensurate to the risk of money laundering and terrorist financing related activities and proportionate to the nature and size of the Bank. These measures are applied with consistency, reviewed on a regular basis and updated, whenever deemed necessary.