Infinity Fintech Solutions s.r.o., a company incorporated, organized and existing under the laws of the Slovak Republic, identification number (IČO): 56 684 428, having its registered address at Doležalova 15C, Bratislava, Slovenská republika (“INFISOL“, “we”, “our”, “us”).
INFISOL is authorized by the Slovakian Chamber of Trade to conduct virtual currency business activity, in particular, services in the exchange of fiat currency for virtual currency, and virtual currency for fiat currency, as well as custodian virtual currency wallet services enabling you to hold, store, transfer, and manage your balances of supported virtual currencies (“Services”).
Virtual currencies are at the core of INFISOL’s business operations, representing one of the most rapidly evolving and transformative sectors in modern financial services. As such, INFISOL dedicates significant resources to identifying, preventing, and addressing risks that may arise in connection with the provision of services involving virtual currencies and related transactions.
To prevent money laundering, financing of terrorism, and other financial crimes while utilizing INFISOL’s services, the company has implemented comprehensive anti-money laundering (AML) and counter-terrorism financing (CTF) policies, founded on strict ethical principles and a commitment to full compliance with relevant laws and regulations. To comply with the existing laws and regulations INFISOL has adopted this Anti-Money Laundering Policy (“Policy”).
INFISOL’s internal AML protocols are designed in accordance with both national and international regulatory requirements and best practices, including:
Act No. 297/2008 Coll. on protection against the legalization of proceeds from criminal activity and protection against the financing of terrorism, adopted on 2 July 2008, as amended (“AML Act”).
Act No. 289/2016 Coll. on the implementation of international sanctions and amending Act No. 566/2001 Coll. on securities and investment services and amending and supplementing certain acts (Securities Act) as amended (“Act 289/2016”).
EU Directive (2018/843) amending Directive (EU) 2015/849 on the prevention of the use of the financial system for money laundering and terrorist financing, and revising Directives 2009/138/EC and 2013/36/EU
EU Directive (2015/849) on the same subject, which also amends Regulation (EU) No 648/2012 and repeals Directive 2005/60/EC and Commission Directive 2006/70/EC
Sanctions and SDN (Specially Designated Nationals) Lists:
EU Consolidated Sanctions and SDN lists
OFAC Sanctions and SDN lists
Compliance with additional international AML/CTF regulations, including recommendations from organizations like FATF, OFAC, and the UN.
INFISOL is obliged to carry out measures against money laundering and terrorist financing. Within this framework, we identify or check our clients.
For the purposes of “Know Your Customer” (KYC), INFISOL collects essential identifying information from each customer applying for its services.
The minimum KYC details required include: full name (First, Last, Middle, Former names if applicable), residential address (including country, postal code, city, and state), date of birth, phone number, and email address.
During the identification process, we verify and record whether you are a politically exposed person or whether they are not a person against whom the Republic of Slovakia applies international sanctions under Act 289/2016. Each customer is obliged to update all the information if there is any change. The customer must ensure that the information is true, complete, and timely updated. If there are any grounds for believing that any of the information customer provided is incorrect, false, outdated, or incomplete, we reserve the right to send the customer a notice to demand correction and, as the case may be, blacklist the existing account and terminate all or part of the services we provide for the said customer.
In addition, INFISOL requests specific documents for KYC and customer due diligence, which include:
A government-issued identity document (valid international passport or national ID card with MRZ code), as well as a proof of address (e.g., utility bill or bank statement). Mobile phone bills, medical invoices, purchase receipts, insurance documents, and screenshots of address documents are not considered acceptable.
This is not an exhaustive list, and INFISOL reserves the right to request additional information and documentation to fully verify the customer, address potential risks, and dispel any doubts about money laundering, terrorism financing, or other unlawful activities.
INFISOL will exert every effort to verify the information within a reasonable time, depending on the nature of the account and risk level of transactions. INFISOL will not complete a transaction before INFISOL has verified the information, or, as the case may be, if INFISOL needs more time to complete the verification procedures INFISOL reserves the right, pending verification, to put on hold transactions and the associated account. If INFISOL discovers suspicious information indicating possible money laundering, terrorist financing activity, or other suspicious activity, INFISOL may file a report to the Financial Intelligence Unit (Finančná spravodajská jednotka).
INFISOL maintains an updated list of non-cooperative jurisdictions, including countries such as Afghanistan, the Bahamas, Belarus, Crimea, Cuba, North Korea (DPRK), Iran, Iraq, Libya, Myanmar, Pakistan, Russia, Syria, parts of Ukraine (Donetsk and Luhansk regions), Venezuela, and others.
INFISOL does not engage in business relationships or provide services to customers who are on any sanctions list, have negative media associations, are residents of or connected to non-cooperative jurisdictions, or intend to use INFISOL’s services for prohibited industries.
INFISOL employs robust systems and tools to identify, assess, and mitigate risks, including a thorough customer verification process, comprehensive AML/CTF risk assessments, transaction monitoring, and the detection of unusual customer activity. INFISOL continuously monitors its customers’ activities to detect and address suspicious behavior promptly.
If a customer requests a refund, INFISOL will carefully assess the request and verify all transaction details. The company may ask the customer to submit specific documents, such as an identity card, a copy of the payment card, a selfie with the card, a bank statement confirming the disputed transaction, or any other evidence supporting the claim of a disputed payment.
Customers are required to provide the requested documentation within three business days from the date of the request. INFISOL reserves the right to decline any refund request if the necessary documents are not provided within the specified time frame.
INFISOL has built a highly skilled and well-trained AML team, fully equipped to handle all aspects of anti-money laundering, counter-terrorism financing, and overall compliance with relevant regulatory requirements.
We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made. Such records can be made available to the competent authorities upon request.
INFISOL’s Money-Laundering Reporting Officer (“MLRO”) is the person appointed and authorized by INFISOL, whose responsibility is to implement and effectively monitor the application and enforcement of this Policy. The MLRO is obliged to oversee and conduct effective monitoring of all aspects of our AML/CFT effort. Any suspicious behavior or activities must be reported to the MLRO at mlro@infisol.net
This Policy shall be deemed an integral part of the Terms and Conditions for Use of Virtual Currency Services and we reserve the right to unilaterally amend or supplement this Policy at any time.
By agreeing to the Terms and Conditions for Use of Virtual Currency Services you acknowledge and confirm that you have read, understood and agreed to be comply with and be bound by the Policy.
