AML & KYC Policy

Last updated: 2 November 2026

SYSTIM Sp. z o.o. (KRS 0001074262, NIP 9581739609, REGON 527165090) is committed to preventing money laundering (ML), terrorist financing (TF) and sanctions violations. This policy is based on the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, EU Directives 2015/849 and 2018/843 (AMLD4/AMLD5), Regulation (EU) 2024/1624 and FATF Recommendations.

1. Compliance officer

The Management Board has appointed an AML Compliance Officer responsible for implementing this policy, monitoring transactions and reporting to the General Inspector of Financial Information (GIIF). Contact: info@systim60.com.

2. Customer due diligence (KYC)

• Identification and verification of the customer using official registers (KRS, CEIDG, REGON, VAT White List).
• Identification of ultimate beneficial owners (UBO) and verification in the Central Register of Beneficial Owners (CRBR).
• Assessment of the purpose and intended nature of the business relationship.
• Enhanced due diligence for high-risk customers, politically exposed persons (PEP) and high-risk third countries.

3. Sanctions screening

Customers and beneficial owners are screened against EU, UN, OFAC and Polish national sanctions lists before onboarding and on an ongoing basis. We do not do business with sanctioned persons or entities.

4. Risk-based approach

Each customer is assigned a risk level (low, standard, high) based on geography, ownership structure, industry and payment behaviour. The level of monitoring is proportionate to the risk.

5. Payments

We accept payments only by bank transfer from accounts held in the customer's name or through regulated payment institutions. We do not accept cash, anonymous prepaid instruments or third-party payments without justification.

6. Monitoring and reporting

Transactions are monitored for unusual patterns. Suspicious activity is reported to GIIF without delay, and assets may be blocked where required by law. Customers are not informed of such reports (tipping-off prohibition).

7. Record keeping

KYC documentation and transaction records are retained for 5 years after the end of the business relationship.

8. Training

All employees receive regular AML/CTF training and must follow internal procedures.

9. Refusal of service

We reserve the right to refuse, suspend or terminate services where a customer fails to provide KYC information or where ML/TF risk cannot be mitigated.