KYC/AML & Sanctions Compliance Policy

Last updated: 28 August 2025Effective date: 28 August 2025

1. Purpose

This KYC / AML & Sanctions Compliance Policy ("Policy") explains how Hazelbit SRL complies with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and international sanctions regulations when providing Services (certificates, NFTs, utility tokens, wallets).

The objective is to:

• Prevent misuse of Hazelbit Services for money laundering, terrorism financing, fraud, or sanctions evasion.

• Ensure transparency of transactions related to NFTs and utility tokens.

• Protect the integrity of Hazelbit, our customers, and the financial system.

2. Scope

This Policy applies to:

• All customers (individuals and businesses) of Hazelbit Services.

• All Hazelbit staff, contractors, and partners.

• All products involving financial transactions, including $HZBT utility tokens and $HZTR NFTs.

3. Regulatory framework

Hazelbit complies with:

EU Regulations

• EU AML Directives (AMLD5, AMLD6)

• Regulation (EU) 2015/847 on wire transfers

• Regulation (EU) 2023/1114 (MiCAR)

National & International

• Romanian AML Law No. 129/2019

• UN, EU, OFAC (US), UK HMT sanctions

4. Know Your Customer (KYC) requirements

a) Individuals must provide:

• Full name, date of birth, nationality.

• Residential address.

• Valid government-issued ID (passport, ID card, or driver's license).

• Tax identification number (if applicable).

• Proof of address (utility bill, bank statement, not older than 3 months).

b) Businesses must provide:

• Company name, legal form, registration number.

• Registered office and country of incorporation.

• Identity of directors and beneficial owners (≥25%).

• VAT number (if applicable).

• Corporate documents (certificate of incorporation, articles of association).

c) Enhanced Due Diligence (EDD):

Hazelbit may request additional documents or checks if:

• The customer is from a high-risk country.

• The transaction value is unusually high.

• The customer is a Politically Exposed Person (PEP).

5. Customer due diligence (CDD) process

Onboarding check

Identity verification before account activation.

Ongoing monitoring

Transactions are monitored for unusual activity.

Periodic review

Risk profile is reassessed at least every 12 months.

Trigger review

Conducted if suspicious activity or red flags appear.

6. Transaction monitoring

Hazelbit monitors:

• Large or unusual NFT/token purchases.

• Transactions involving multiple wallets in a short period.

• Use of privacy tools (mixers, tumblers, anonymity-enhanced coins).

• Links to sanctioned or high-risk jurisdictions.

Suspicious activity is escalated to the AML Compliance Officer.

7. Record keeping

KYC data:retained for 5 years after the end of the business relationship.
Transaction records:retained for 10 years (tax & AML compliance).
Blockchain records:immutable and public; may be linked to your account.

8. Sanctions compliance

Hazelbit does not provide Services to:

• Individuals or entities on EU, UN, US (OFAC), or UK sanctions lists.

• Residents of jurisdictions subject to comprehensive sanctions (e.g., North Korea, Iran, Syria, Crimea, Cuba, Afghanistan, Russia-related restrictions where applicable).

• Persons attempting to evade sanctions through proxies.

9. Reporting obligations

Hazelbit will report suspicious activity to:

• Oficiul Național de Prevenire și Combatere a Spălării Banilor (ONPCSB, Romania's FIU).

• Other competent EU authorities when required.

10. Staff responsibilities

• Hazelbit designates an AML Compliance Officer responsible for oversight.

• All relevant employees receive AML/KYC training annually.

• Breaches of this Policy may result in disciplinary action.

11. Customer responsibilities

By using Hazelbit Services, you agree to:

• Provide true, accurate, and complete KYC information.

• Update information if your circumstances change.

• Cooperate with Hazelbit in case of additional AML/KYC checks.

12. Consequences of non-compliance

Hazelbit may, without liability:

• Refuse transactions.

• Freeze or suspend accounts.

• Terminate the business relationship.

• Report you to authorities.

13. Contact

For AML/KYC questions:

Hazelbit SRL

Str. Fântânilor 43, Bl. B14, Ap. B39, Iași, Romania

Email:info@hazelbit.ro