KYC &

AML POLICY

CLICKABLE (hereinafter may referred to as "Clickable", "We" or "Us") undertakes to adhere to the actual anti-money laundering and countering the financing of terrorism rules, conducting activities through its website: https://clickable.agency/

1. INTRODUCTION

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy (hereinafter - Policy) sets out the principles and procedures adopted by Clickable to ensure compliance with applicable laws and regulations in the EU, UK and US, including but not limited to the EU AML Directives, СFT rules and U.S. Bank Secrecy Act (BSA) enforced by FinCEN.

2. SCOPE OF APPLICATION

This Policy applies to all users, clients, partners and other individuals and entities with whom Clickable establishes business relationships, including third parties. It covers both onboarding and ongoing monitoring activities.

3. OBJECTIVES

• To uphold Clickable’s business integrity and reputation;

• To prevent involvement in money laundering, terrorist financing, and fraudulent schemes;

• To ensure transparency in all interactions with Users and establish a risk-based approach to their due diligence.

• To ensure compliance with relevant legal and regulatory obligations.

4. ROLES AND RESPONSIBILITIES

• Clickable’s Compliance Officer is responsible for implementing and enforcing this KYC/AML Policy; and also oversight, implementation, training, and reporting.

• All employees are required to complete annual compliance training and report any suspicious activity. 

5. DUE DILIGENCE (DD)

5.1. Registration Due Diligence including Verification of accounts and submitted User Account Data,: email address, messenger IDs (e.g., Skype/Telegram), IP addresses, and payment details. For legal entities the following must be provided:

• Incorporation documents;

• Information on Ultimate Beneficial Owners (UBOs);

• Proof of tax identification numbers (TIN, VAT ID, EIN, etc.). Sanctions screening will be performed against OFAC, EU Consolidated List, UN, UK HMT, and other applicable lists.

5.2. Enhanced Due Diligence (EDD) is required in cases involving:

• Engagement with individuals or entities from high-risk jurisdictions;

• Identification of Politically Exposed Persons (PEPs);

• Suspected fictitious or anomalous activity, such as unusual clicks or artificial traffic.

EDD measures may include:

• Requests for recent bank statements;

• Verification of source of funds;

• Live video verification of authorized representatives.

7. MONITORING AND REPORTING

Ongoing monitoring of financial activity is conducted via Clickable’s integrated tracking system. Accounts may be suspended and investigated in cases of:

• Suspicious activity;

• Violations of the Terms of Use (e.g., use of illicit content, fraud, automated scripts);

• Anonymous or unauthorized login attempts. 

8. DATA RETENTION

All KYC/AML documentation is retained:

• For at least five (5) years following the termination of a business relationship;

• In compliance with GDPR and relevant FinCEN data retention requirements. 

9. CONFIDENTIALITY

All user and payment data are processed in accordance with Clickable’s Privacy Policy. Information may be disclosed to competent authorities upon official request (see Section 12.2 of the Terms of Use). 

10. REPORTING SUSPICIOUS ACTIVITY

Suspicious activities must be reported internally to the Compliance Officer. If necessary, the agency may report to:

• FIU in the EU member state of incorporation.

• FinCEN in the United States.

11. REVIEW AND UPDATES

This policy will be reviewed at least annually and updated as necessary to reflect regulatory changes or operational risk factors.

This Policy was last updated on June 01,  2025