AML / CTF Policy

Anti-Money Laundering and Counter-Terrorist Financing Policy

Last updated: 14 April 2026

Responsible Entity

ALEKSANDAR ZLATKOVIĆ PR AGENCIJA ZA VEB PORTALE SEBN OBRENOVAC

PIB: 108083132 · Matični broj: 63200859

Miloša Obrenovića 135/2, Obrenovac, Beograd-Obrenovac, Republika Srbija

1. Policy Statement

Zlatcoin is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy is established in accordance with the Law on Prevention of Money Laundering and Financing of Terrorism (Republic of Serbia) and applicable EU directives, including the 6th Anti-Money Laundering Directive (6AMLD). We will not knowingly facilitate any transaction that involves the proceeds of criminal activity or that supports terrorist financing.

2. Know Your Customer (KYC) Requirements

All users must complete identity verification before accessing financial features of the Platform. Our KYC process includes the following steps:

Verification Level	Requirements	Features Unlocked
Level 0 — Unverified	Email registration only	Dashboard, ZLC credits (limited), market data
Level 1 — Basic	Government-issued ID + selfie	AI Trade (simulated), Gold Market, full credits
Level 2 — Enhanced	Level 1 + proof of address	Live trading, API key integration, higher limits

3. Prohibited Persons and Jurisdictions

We do not provide services to individuals or entities that are: (a) located in, or nationals of, countries subject to comprehensive sanctions (including but not limited to North Korea, Iran, Syria, Cuba, and Crimea); (b) listed on any applicable sanctions list, including the UN Security Council Consolidated List, EU Consolidated Sanctions List, or OFAC SDN List; or (c) politically exposed persons (PEPs) without enhanced due diligence.

4. Suspicious Activity Monitoring

We monitor Platform activity for indicators of suspicious behavior, including but not limited to:

Unusual patterns of transactions inconsistent with the user's stated profile
Attempts to circumvent KYC requirements or provide false documentation
Multiple accounts linked to the same individual or IP address
Transactions involving jurisdictions with high AML risk ratings
Sudden large increases in activity without apparent legitimate purpose

5. Reporting Obligations

Where we identify suspicious activity, we are obligated to file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit (Administration for the Prevention of Money Laundering, Republic of Serbia). We are prohibited by law from notifying the subject of a SAR filing ("tipping off"). Account access may be suspended pending investigation.

6. Record Keeping

We retain all KYC documentation, transaction records, and AML-related correspondence for a minimum of 5 years following the end of the business relationship, as required by applicable law. Records are stored securely and accessible only to authorized personnel.

7. Contact

For AML-related inquiries or to report suspicious activity, contact our Compliance Officer at: [email protected]