AML Policy

Last Update: December 7, 2025

Dream Finance OÜ (“CoinsPaid” / “Company“) has no tolerance for money laundering, the financing of terrorism or any other form of illicit activity, and is committed to implementing policies, procedures and controls shaped by the best industry practices and the most effective anti-money laundering standards applied in the Republic of Estonia and worldwide. These rules apply to, without exception, all employees of the Company, its Board members, officers, contractors, and consultants.

The purpose of this document is to provide the Company’s partners, clients, vendors, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company’s AML/CTF compliance regime elements and procedures. By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity.

This document and all underlying policies, processes and procedures are prepared in line with provisions, requirements and recommendations of:

Money Laundering and Terrorist Financing Prevention Act of Estonia (RahaPTS), as amended from time to time;
International Sanctions Act of Estonia, as amended from time to time;
Guidance and recommendations issued by the Estonian Financial Intelligence Unit (FIU) and other competent supervisory authorities;
FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (VASPs).

The Company operates from, and under the laws of the Republic of Estonia. Estonia was among the first countries in the world who introduced Anti-money laundering (“AML“) and countering the financing of terrorism (“CTF“) requirements for businesses engaged in exchange of virtual currency for fiat currency and virtual currency custody back in 2017. As a result, each entity rendering named services from or within the territory of Estonia must apply for authorization to the Estonian Financial Intelligence Unit (FIU).

Dream Finance OÜ is authorised by the Estonian Financial Intelligence Unit (FIU) to provide virtual currency exchange services and virtual currency wallet services under licence number FVT000166. Licensing information can be verified on the official website of the Ministry of Economic Affairs and Communications of Estonia.

As a regulated business, the Company is required to comply with the Money Laundering and Terrorist Financing Prevention Act of Estonia and the International Sanctions Act. These obligations require the Company to identify and verify its customers, conduct ongoing monitoring of their activity (including transaction monitoring), maintain records and documents for the legally prescribed retention period, and report certain activities or suspicions to the competent authorities.

The Company understands money laundering in accordance with applicable legislation as including, inter alia:

the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising its illicit origin or assisting any person involved in such activity to evade legal consequences;
the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity;
the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity;
participation in, attempts to commit, aiding, abetting or facilitating any of the acts referred to above.

Terrorist financing provides funds or other assets for terrorist activity. From a legal standpoint, it means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used, or in the knowledge that they are to be used, in full or in part, to carry out terrorist acts as defined in applicable international conventions and Estonian law. Terrorist activity is generally aimed at intimidating a population or compelling a government or international organisation to act or refrain from acting. This may be done by intentionally killing or seriously harming people, endangering life, causing substantial property damage likely to seriously harm people, or seriously interfering with or disrupting essential services, facilities or systems.

Risk-Based Approach and Risk Assessment

The Company applies a risk-based approach to all prospective clients. The Company collects and evaluates information and documentation necessary to assess the money laundering, terrorist financing and sanctions risks associated with each customer. Employees of the Company exercise due care and professional judgment when assessing the customer’s risk profile, taking into account factors such as customer type, geographical exposure, products and services used, delivery channels and transactional behaviour. The Company conducts its business in accordance with the highest ethical and regulatory standards and will not enter into business relationships with individuals or entities whose activities may pose unacceptable legal, reputational or regulatory risks or otherwise fall outside the Company’s risk appetite.

For the purpose of identifying, assessing and analysing the risks of money laundering, terrorist financing and sanctions exposure related to its activities, the Company performs a Customer Risk Assessment. This assessment takes into account the following categories:

Customer risk;
Geographical Risk;
Product Risk;
Delivery Channel;
Behavioral or Transactional Risk.

Each customer is assigned a risk level based on these factors. The assigned risk level is reviewed periodically and updated where necessary, taking into consideration changes in the customer’s profile, behaviour, business activity or any other information obtained during ongoing due diligence and transaction monitoring.

Money Laundering Reporting Officer

The management board of the Company appoints a Money Laundering Reporting Officer (MLRO), who acts as the Company’s designated contact person for the Estonian Financial Intelligence Unit (FIU) and is responsible for the implementation and oversight of the Company’s AML/CTF framework. The MLRO reports directly to the management board and has the authority, resources and unrestricted access to all information necessary to perform these duties across all structural units of the Company.

Only a person who has the education, professional suitability, abilities, personal qualities, experience and impeccable reputation required for the performance of these duties may be appointed as the MLRO. The appointment of the MLRO is coordinated with the FIU in accordance with applicable legal requirements.

The duties of the MLRO include, inter alia:

organising the collection and analysis of information related to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing that become apparent in the activities of the Company;
reporting to the Estonian Financial Intelligence Unit (FIU) without delay in the event of suspicion of money laundering or terrorist financing;
submitting periodic written reports to the management board of the Company regarding compliance with the requirements arising from the applicable legislation;
performing any other duties and obligations related to ensuring compliance with the Anti-Money Laundering and Counter-Terrorist Financing requirements applicable to the Company.

Rules of Procedure and Internal Control Rules

The Company has developed and implemented internal rules of procedure that enable the effective mitigation and management of money laundering, terrorist financing and sanctions risks identified through its risk-based approach. All employees of the Company are required to comply with these rules of procedure.

The internal rules of procedure include, inter alia:

the application of customer due diligence measures, including enhanced due diligence where appropriate;
the identification and assessment of customer-related risks and the determination of the customer’s risk profile;
the methodology and internal instructions to be followed when the Company identifies unusual activity or suspects money laundering or terrorist financing, including procedures for fulfilling reporting obligations to the competent authorities;
the procedures for data retention and ensuring the availability of records in accordance with applicable legal requirements;
instructions for identifying politically exposed persons and persons subject to international sanctions.

The Company applies the following customer due diligence measures:

identifying the customer and verifying the information provided using reliable and independent sources, including electronic identification tools and trusted electronic verification services;
identifying the beneficial owner and taking appropriate steps to verify their identity and to understand the customer’s ownership and control structure;
understanding the nature and purpose of the business relationship and, where relevant, obtaining additional information to support this assessment;
determining whether a customer or related person is a politically exposed person (PEP), a family member of a PEP or a close associate of a PEP;
conducting ongoing monitoring of the business relationship to ensure that transactions and customer activity are consistent with the Company’s knowledge of the customer and their risk profile.

Enhanced Due Diligence (EDD)

The Company applies enhanced due diligence measures in situations where the risk of money laundering or terrorist financing is higher than usual, or where additional verification is required to ensure that the risks associated with a customer can be effectively managed and mitigated.

EDD measures are applied in particular when:

during identification or verification, doubts arise regarding the accuracy of the information provided, the authenticity of documents, or the identification of the beneficial owner;
the customer, beneficial owner or a related person is identified as a politically exposed person (PEP) or a close associate or family member of a PEP;
the customer is associated with, or originates from, a high-risk third country as defined under applicable AML legislation.

The Company applies EDD whenever its risk assessment determines that the nature of the customer’s business, activity, behaviour or other relevant factors present a higher-than-usual risk of money laundering or terrorist financing.

PEP Definition and Screening

The Company applies enhanced due diligence measures to politically exposed persons (PEPs), as well as to their family members and close associates, in accordance with international standards and applicable legislation. PEPs may present a higher risk of money laundering or corruption due to the influence and authority associated with their public roles.

A PEP is a natural person who is or has been entrusted with prominent public functions, including:

head of state or head of government;
minister, deputy minister or assistant minister;
member of parliament or a similar legislative body;
senior official of a political party;
member of a supreme court or other high-level judicial body;
member of a court of auditors or the board of a central bank;
ambassador, chargé d’affaires or high-ranking military officer;
senior executive of a state-owned enterprise;
director, deputy director or member of the management or supervisory body of an international organisation.

Family members of a PEP include:

the spouse or a person considered equivalent to a spouse;
the children of a PEP and their spouses or persons considered equivalent to spouses;
the parents of a PEP.

Close associates of a PEP include natural persons who:

are known to have joint beneficial ownership of legal entities or arrangements with a PEP, or have other close business relationships with a PEP; or
have sole beneficial ownership of a legal entity or arrangement that is known to have been established for the benefit of a PEP.

The Company screens customers, beneficial owners and related persons against PEP information as part of its due diligence measures and applies enhanced monitoring where required.

Sanctions Screening

The Company recognises that dealing with persons or entities subject to international sanctions presents significant legal and regulatory risks. The Company therefore conducts sanctions screening as part of its customer due diligence and ongoing monitoring processes.

The Company screens customers, beneficial owners and relevant associated persons against applicable sanctions lists, including at minimum:

United Nations (UN) sanctions;
European Union (EU) sanctions;
sanctions administered by the Office of Financial Sanctions Implementation (OFSI, United Kingdom);
sanctions administered by the Office of Foreign Assets Control (OFAC, United States);
sanctions imposed under the International Sanctions Act of Estonia.

Any confirmed match (“true hit”) is immediately escalated to the MLRO for assessment and further action in accordance with applicable legal obligations. The Company does not establish or continue business relationships where sanctions risks cannot be effectively mitigated.

Suspicious Activity Monitoring and Reporting

If the Company identifies activity or circumstances that may indicate the use of criminal proceeds, terrorist financing, or any other criminal offence or attempt thereof, or if the Company knows or suspects that a transaction or activity may constitute money laundering or terrorist financing, the MLRO must report such activity to the Estonian Financial Intelligence Unit (FIU) without delay and no later than within two working days from identifying the relevant facts or forming the suspicion.

The Company and all its employees, officers and directors are strictly prohibited from informing the customer, their beneficial owner, representative or any third party about a report submitted to the FIU, the intention to submit such a report, or the existence of an investigation or criminal proceedings. This prohibition on “tipping off” is mandatory under applicable law.

Data Retention

The Company retains customer identification data, verification records, transaction information and other documents required under applicable AML/CTF legislation for the legally prescribed retention period, which is generally eight years from the end of the business relationship or completion of the relevant transaction.

The Company implements appropriate measures to ensure the protection and confidentiality of personal data in accordance with applicable data protection laws. Personal data obtained for the purposes of customer due diligence and ongoing monitoring is processed solely for the prevention of money laundering and terrorist financing and is not used for any unrelated purposes, including marketing.

Training

The MLRO ensures that all employees of the Company are aware of their legal obligations in the area of anti-money laundering, counter-terrorist financing and sanctions compliance by implementing a comprehensive training programme.

The content and frequency of training are determined based on the Company’s risk profile, regulatory developments, employees’ responsibilities and changes in the business model. Training is provided upon hiring and on a regular basis thereafter, and it may be supplemented whenever necessary to reflect updates in legislation, emerging risks or new typologies.

The training programme is designed to ensure that employees understand the applicable legal requirements, the risks associated with money laundering and terrorist financing, the Company’s internal systems and controls, and the procedures for identifying and reporting suspicious activity.

Cooperation and Exchange of Information

The Company cooperates with supervisory authorities and law enforcement agencies in the prevention and detection of money laundering, terrorist financing and sanctions violations. The Company provides information and responds to requests from competent authorities in a timely manner and in accordance with applicable legal obligations, including data protection and confidentiality requirements.

For official requests for information, please contact: [email protected].

If the requesting authority is located outside the European Union, the provision of information may be subject to international cooperation procedures such as the Mutual Legal Assistance Treaty (MLAT) or other applicable legal frameworks.