Anti-Money Laundering and Counter-Terrorist Financing Policy (AML / CFT Policy)

1. General Statement

1.1. The charitable organization 2xEnergy MTÜ, incorporated under the laws of the Republic of Estonia, with its registered address at: Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Telliskivi tn 57, 10412 (hereinafter – the “Foundation”), is committed to preventing money laundering, terrorist financing, fraud, and other unlawful activities.

1.2. The Foundation operates in accordance with:

  • the laws of the Republic of Estonia;
  • European Union regulations;
  • FATF recommendations;
  • international sanctions regimes.

1.3. This Policy defines the Foundation’s approach to risk management and compliance with AML/KYC requirements.

2. Nature of Activities and Scope

2.1. The Foundation is a non-profit organization engaged in charitable activities.

2.2. This Policy applies to:

  • all donors (individuals and legal entities);
  • beneficiaries;
  • partners;
  • all transactions, including:
  • bank transfers;
  • payments via payment systems;
  • cryptocurrency donations.

2.3. The Foundation is not a financial institution but adheres to AML/KYC standards within the scope of its activities.

3. Risk-Based Approach

3.1. The Foundation applies a risk-based approach to assess:

  • geographic risks (high-risk jurisdictions);
  • customer risks (type of donor);
  • transaction risks (volume, frequency, structure);
  • payment channels (fiat / crypto).

3.2. Based on the assessment, the following may be applied:

  • Simplified Due Diligence (SDD);
  • Customer Due Diligence (CDD);
  • Enhanced Due Diligence (EDD).

4. KYC Procedures (Know Your Customer)

The Foundation may identify donors before or after accepting a donation.

4.1 For Individuals:

  • full name;
  • date of birth;
  • residential address;
  • copies of identification documents (passport, ID card);
  • proof of address (utility bill, bank statement).

4.2 For Legal Entities:

  • company name;
  • registration number;
  • registered address;
  • information about directors;
  • Ultimate Beneficial Owner (UBO) information;
  • ownership structure.

4.3 Verification:

  • use of official registers;
  • verification via third-party KYC/AML providers;
  • ongoing monitoring.

4.4. The Foundation reserves the right to refuse donations where KYC requirements are not fulfilled.

5. Source of Funds Verification

5.1. The Foundation may request information regarding:

  • origin of funds;
  • source of income;
  • economic purpose of the transaction.

5.2. Enhanced Due Diligence (EDD) applies to large or suspicious donations.

6. Cryptocurrencies and Blockchain Monitoring

6.1. The Foundation accepts cryptocurrency donations, taking into account elevated risks.

6.2. The following measures may be applied:

  • blockchain analytics tools;
  • screening of addresses for links to:
  • darknet;
  • sanctioned entities;
  • fraudulent activity.

6.3. The Foundation reserves the right to:

  • refuse cryptocurrency donations;
  • suspend interaction;
  • report to relevant authorities.

7. Sanctions Screening

7.1. The Foundation conducts screening against:

  • European Union sanctions lists;
  • United Nations sanctions lists;
  • OFAC (United States);
  • HM Treasury (United Kingdom).

7.2. Screening is conducted:

  • prior to donation acceptance (where possible);
  • after transactions (retrospective checks);
  • on an ongoing basis.

7.3. The Foundation does not accept donations from sanctioned individuals or entities.

8. Transaction Monitoring

8.1. The Foundation monitors transactions to detect:

  • unusual amounts;
  • atypical patterns;
  • structuring (smurfing);
  • inconsistencies with donor profile.

8.2. Both internal and third-party tools may be used.

9. Reporting Suspicious Transactions

9.1. In case of suspicious activity, the Foundation:

  • conducts internal investigation;
  • documents findings.

9.2. Where required, the Foundation:

  • reports to the Financial Intelligence Unit (FIU) of Estonia;
  • cooperates with regulators.

9.3. Disclosure to the donor regarding such reporting (tipping-off) is prohibited.

10. Refusal of Donations

The Foundation reserves the right to:

  • refuse a donation;
  • return funds (where possible);
  • terminate interaction with a donor,

in cases of:

  • non-compliance with AML/KYC requirements;
  • suspicious activity;
  • lack of required information.

11. Record Keeping

11.1. The Foundation retains:

  • KYC documentation;
  • transaction data;
  • verification results;
  • AML decisions and reports.

11.2. Retention period:

  • at least 5 years;
  • or longer if required by law.

12. Internal Control and AML Officer

12.1. The Foundation appoints an AML Officer.

12.2. The AML Officer is responsible for:

  • implementation of this Policy;
  • compliance oversight;
  • interaction with regulators;
  • internal monitoring.

13. Training and Awareness

The Foundation ensures that responsible persons receive training on:

  • AML/KYC;
  • sanctions compliance;
  • risk identification;
  • reporting procedures.

14. Policy Updates

This Policy is reviewed:

  • at least annually;
  • upon changes in legislation;
  • upon changes in the risk profile.

15. Governing Law

This Policy is governed by and construed in accordance with the laws of the Republic of Estonia.

Any disputes shall be resolved by competent courts of Estonia, including courts located in Tallinn.

16. Contact Information

If you have any questions regarding this Policy, you may contact the Foundation:

Email: info@2x.energy

Address: Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Telliskivi tn 57, 10412