AML & KYC Policy

Our commitment to preventing financial crime

Novus Capital operates a zero-tolerance approach to money laundering and the financing of terrorism. We are committed to conducting our business honestly and to preventing our platform from being used, knowingly or unknowingly, to facilitate financial crime.

We maintain internal controls, policies, and procedures designed to identify and manage the risk that our services could be misused, and we keep them under regular review so that they remain effective and reflect current law and guidance.

Regulatory framework

We are established in the Republic of Bulgaria and operate under Bulgarian and European Union law. Our anti-money-laundering and counter-terrorist-financing ("AML/CFT") obligations arise principally under the Bulgarian Measures Against Money Laundering Act and the Measures Against the Financing of Terrorism Act, which implement the European Union's anti-money-laundering directives.

We cooperate with the competent Bulgarian authorities, including the Financial Intelligence Directorate of the State Agency for National Security, and we comply with the reporting and record-keeping duties those laws place on us.

Customer due diligence and identity verification

Before you can invest, and at appropriate points afterwards, we carry out customer due diligence ("CDD") — the checks that allow us to know who our users are. We perform identity verification with the help of Sumsub, a specialist identity-verification provider that processes your identity documents and verification data on our behalf and under our instructions.

As part of customer due diligence we typically verify:

• your identity, using a government-issued identity document and, where required, a photograph or short video to confirm it belongs to you;
• your date of birth, nationality, and residential address;
• that you are acting on your own behalf and not for an undisclosed third party;
• the purpose and intended nature of your relationship with the platform.

We may ask for additional information or documents at any time, and we may suspend or restrict an account until the checks we require have been completed satisfactorily.

Enhanced due diligence

In situations that present a higher risk of money laundering or terrorist financing, we apply enhanced due diligence — additional checks beyond our standard procedures. We do this, for example, where:

• a user is a politically exposed person, or a family member or close associate of one;
• a user is established in, or connected to, a country identified as high-risk;
• a transaction is unusually large or complex, or has no apparent economic or lawful purpose;
• there is any other factor that indicates an elevated risk.

Enhanced due diligence may include obtaining further information about the source of funds and source of wealth, seeking senior-management approval to continue the relationship, and monitoring the account more closely.

Ongoing monitoring

Customer due diligence does not stop once your account is open. We monitor activity on the platform on an ongoing basis to make sure it is consistent with what we know about you and with the expected use of our services, and to identify activity that appears unusual or suspicious.

We keep the information we hold about you up to date, and we may repeat or refresh our checks periodically or when your circumstances change.

Sanctions screening

We screen our users against applicable international, European Union, and national sanctions lists, both when an account is opened and on an ongoing basis. We do not provide services to any person or entity that is subject to sanctions, and we will freeze funds and decline transactions where we are legally required to do so.

Source of funds

You may invest only with funds that belong to you and that come from a legitimate source. We may ask you to demonstrate the origin of the funds you deposit or invest, and to provide supporting evidence. We may decline, delay, or reverse a transaction, or restrict an account, where the source of funds cannot be established to our satisfaction.

Reporting suspicious activity

Where we know or suspect, or have reasonable grounds to know or suspect, that funds or activity are linked to money laundering or terrorist financing, we are legally required to report this to the competent authorities. We make such reports confidentially, and the law prohibits us from tipping off the person concerned.

We may suspend or terminate a transaction or an account, without prior notice, where this is necessary to comply with our legal obligations.

Record keeping

We keep the records generated by our customer due diligence, monitoring, and reporting — including copies of identification, verification data, and transaction records — for the period required by law, which is generally at least five years after the end of our relationship with you, unless a longer period is required. These records are handled in accordance with our Privacy Policy.

Responsible officer and staff training

We have appointed a responsible officer accountable for our AML/CFT programme, with authority to oversee our controls and to make reports to the competent authorities. We provide our staff with training appropriate to their roles so that they can recognise and respond to the risks of money laundering and terrorist financing.

What we do not accept

To protect the platform and comply with our obligations, we do not accept:

• cash, or payments made in cash;
• funds deposited by, or paid to, a third party — every deposit and withdrawal must be made in your own name, from and to an account held in your name;
• funds we believe to originate from, or to be intended for, unlawful activity;
• any attempt to use the platform anonymously or under a false or borrowed identity.

Attempting to circumvent these requirements may result in the suspension or closure of your account and, where appropriate, a report to the competent authorities.

How to contact us

If you have any questions about this policy, or need to provide information in connection with our anti-money-laundering checks, you can contact us using the contact details published on our website.