As a provider of digital asset and payment-related services, Sole Technologies recognizes its responsibility to prevent its products, services, systems, and infrastructure from being used for money laundering, terrorist financing, sanctions evasion, fraud, corruption, or any other form of financial crime.
The Company maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing ("AML/CTF") framework designed to comply with:
Applicable Bulgarian legislation;
European Union AML legislation;
International sanctions requirements;
Financial Action Task Force ("FATF") recommendations;
Markets in Crypto-Assets Regulation ("MiCA");
Other applicable laws and regulatory standards.
2. RISK-BASED APPROACH
Sole Technologies adopts a risk-based approach to AML/CTF compliance.
The Company continuously assesses and manages risks associated with:
Customers;
Products and services;
Delivery channels;
Geographic exposure;
Transactions;
Business relationships.
Enhanced controls are applied where higher risks are identified.
3. CUSTOMER DUE DILIGENCE (CDD)
Prior to establishing a business relationship or providing regulated services, Sole Technologies performs customer due diligence procedures.
Depending on the customer type and risk profile, this may include:
Individual Customers
Full legal name;
Date of birth;
Residential address;
Nationality;
Government-issued identification;
Selfie or biometric verification;
Verification of identity documentation.
Corporate Customers
Certificate of incorporation;
Constitutional documents;
Shareholder structure;
Director information;
Ultimate beneficial owner ("UBO") identification;
Proof of business activities;
Corporate address verification.
4. ENHANCED DUE DILIGENCE (EDD)
Additional due diligence measures may be applied in higher-risk situations.
Enhanced Due Diligence may include:
Source of funds verification;
Source of wealth verification;
Additional documentary evidence;
Independent information verification;
Senior management approval;
Ongoing enhanced monitoring.
EDD may be applied to:
Politically Exposed Persons ("PEPs");
High-risk jurisdictions;
Complex ownership structures;
Higher-risk business activities;
Unusual transaction patterns.
5. SANCTIONS COMPLIANCE
Sole Technologies maintains sanctions screening procedures designed to ensure compliance with applicable international sanctions regimes.
Customers, beneficial owners, counterparties, and transactions may be screened against sanctions lists issued by, among others:
European Union (EU);
United Nations (UN);
Office of Foreign Assets Control (OFAC);
United Kingdom HM Treasury (OFSI);
Other competent authorities.
The Company reserves the right to:
Reject transactions;
Refuse onboarding;
Suspend services;
Freeze assets where legally required.
6. POLITICALLY EXPOSED PERSONS (PEPS)
The Company identifies and assesses relationships involving Politically Exposed Persons ("PEPs"), their family members, and close associates.
Additional measures may include:
Enhanced due diligence;
Senior management approval;
Ongoing enhanced monitoring;
Periodic review of the relationship.
7. TRANSACTION MONITORING
Sole Technologies performs ongoing transaction monitoring to detect unusual, suspicious, or potentially prohibited activities.
Monitoring may include:
Automated monitoring systems;
Manual reviews;
Blockchain analytics;
Behavioral analysis;
Risk scoring methodologies.
Transactions may be reviewed before, during, or after execution.
8. BLOCKCHAIN ANALYTICS
Where appropriate, Sole Technologies utilizes blockchain intelligence and analytics tools to identify and mitigate risks associated with crypto-asset transactions.
Blockchain analysis may be used to identify exposure to:
Sanctioned entities;
Darknet marketplaces;
Fraud schemes;
Mixing services;
Ransomware activity;
Illicit activities.
The Company may refuse transactions presenting unacceptable risk.
9. SUSPICIOUS ACTIVITY REPORTING
Where suspicious activity is identified, Sole Technologies may be legally required to:
Investigate the activity;
Escalate internally;
Report suspicious transactions to competent authorities;
Restrict or terminate customer relationships.
The Company may be prohibited by law from informing customers that such reports have been made.
10. RECORD KEEPING
Sole Technologies maintains records relating to:
Customer identification;
Due diligence documentation;
Transactions;
Compliance reviews;
Risk assessments.
Records are retained in accordance with applicable legal and regulatory requirements.
11. TRAINING AND GOVERNANCE
The Company maintains internal governance arrangements designed to ensure effective AML/CTF compliance.
This includes:
Appointment of responsible compliance personnel;
Ongoing employee training;
Independent reviews and audits;
Internal policies and procedures;
Senior management oversight.
12. PROHIBITED ACTIVITIES
Sole Technologies strictly prohibits the use of its Services for activities involving:
Money laundering;
Terrorist financing;
Fraud;
Sanctions evasion;
Human trafficking;
Child exploitation;
Corruption;
Market abuse;
Illegal gambling;
Unlicensed financial activities;
Any other unlawful conduct.
Customers engaging in prohibited activities may have their accounts suspended or terminated without prior notice.
13. COOPERATION WITH AUTHORITIES
Sole Technologies cooperates with competent regulatory, supervisory, judicial, and law enforcement authorities as required by applicable law.
The Company may disclose information where legally obligated to do so.
14. CUSTOMER RESPONSIBILITIES
Customers are responsible for:
Providing accurate information;
Promptly updating information;
Cooperating with compliance requests;
Providing supporting documentation when requested.
Failure to cooperate may result in delays, restrictions, suspension, or termination of services.
15. CONTACT
Questions relating to AML/CTF matters may be directed to:
Compliance Department
Sole Technologies Ltd.
Email: [email protected]
Website: https://www.sole-pay.com
Registered Office:
25 Angel Kanchev Street,
Sofia 1000, Republic of Bulgaria