AML Policy

Effective since: August 01, 2025

Last updated: August 07, 2025

1. Introduction

Revalcoin.com, operated by Multidot OÜ (registry code 14499629), is committed to preventing its platform from being used for money laundering (ML) or terrorist financing (TF). This policy outlines our core principles and procedures for complying with applicable regulations, including the EU Anti-Money Laundering Directives (AMLD), the Markets in Crypto-Assets Regulation (MiCA), and the laws of Estonia and Poland.

2. Zero Tolerance for Financial Crime

We adopt a strict risk-based approach and maintain a conservative risk appetite. We primarily serve Low-Risk and Standard-Risk clients. Relationships with High-Risk clients are generally prohibited and may only be established in exceptional circumstances with senior management approval.

3. Core Compliance Principles

Customer Due Diligence (CDD): We identify and verify all our customers (Know Your Customer or KYC) before providing services.
Enhanced Due Diligence (EDD): We apply stricter measures for higher-risk scenarios, such as transactions involving Politically Exposed Persons (PEPs) or highrisk jurisdictions.
Ongoing Monitoring: We continuously monitor transactions and business relationships for suspicious activity.
Record Keeping: We retain all KYC and transaction data for a minimum of 5 years after the end of the business relationship.
Reporting: We promptly report any suspicious activity to the relevant Financial Intelligence Units (FIUs).

4. Our Procedures in Practice

Identity Verification: We use our official KYC partner, Sum and Substance Ltd, to securely verify customer identities using government-issued IDs, liveness checks, and biometric data.
Screening: All customers are automatically screened against global sanctions lists, PEP databases, and adverse media sources.
Transaction Monitoring: We employ advanced blockchain analytics tools (KYT - Know Your Transaction) to monitor transactions in real-time for patterns indicative of ML/TF.

5. Prohibited Activities

Revalcoin.com does not:

Accept anonymous customers or transactions.
Maintain accounts with anonymous or fictitious names.
Accept cash payments directly.
Establish relationships with shell banks or entities from non-cooperative jurisdictions.

6. Compliance Officer

Our Compliance Officer oversees the implementation of this policy and serves as the point of contact for regulatory authorities.

Igor Oja, Compliance Officer / MLRO

Email: support@revalcoin.com

7. Cooperation with Authorities

We fully cooperate with law enforcement and regulatory bodies, including the Estonian FIU (RAB) and the Polish Financial Supervision Authority (KNF), in accordance with the law.

8. Policy Review

This policy is reviewed and updated annually, or more frequently as needed to reflect changes in regulations and emerging risks.