AML / KYC Policy

Last updated: 9 March 2026

SIA SILVALAND

1. Introduction

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy describes the procedures and controls implemented by SIA SILVALAND (“Silvaland”, “Company”, “we”, “our”, or “us”) to prevent money laundering, terrorist financing, fraud, and other illegal financial activities through the Silvaland forest investment platform.

Silvaland is committed to complying with applicable anti-money laundering regulations of Latvia, the European Union, and international AML standards.

This policy applies to all users, investors, partners, and employees involved with the Silvaland platform.

2. Legal Framework

Silvaland operates in accordance with the following legal and regulatory frameworks:

• EU Anti-Money Laundering Directive (AMLD)
• General Data Protection Regulation (GDPR)
• Latvian Law on the Prevention of Money Laundering and Terrorism Financing
• International AML recommendations issued by the Financial Action Task Force (FATF)

3. Purpose of AML / KYC Procedures

The purpose of Silvaland’s AML/KYC program is to:

• Prevent money laundering and terrorist financing
• Verify the identity of platform users and investors
• Detect suspicious financial activities
• Ensure compliance with applicable laws and regulations
• Protect the integrity of the Silvaland investment platform

4. Customer Identification (KYC)

Before gaining access to investment services, users may be required to complete identity verification procedures.

Individual Investors

Silvaland may collect the following information:

• Full legal name
• Date of birth
• Nationality
• Residential address
• Email address and phone number
• Government-issued identification (passport or ID card)

Additional documents may include:

• Proof of address (utility bill or bank statement)
• Selfie or biometric verification
• Additional documentation if required for enhanced due diligence

Corporate Investors

For corporate entities, Silvaland may require:

• Company registration documents
• Certificate of incorporation
• Registered address
• Names of directors and authorized representatives
• Identification documents of beneficial owners
• Corporate ownership structure

Silvaland may also identify the Ultimate Beneficial Owner (UBO) of the company.

5. Risk-Based Approach

Silvaland applies a risk-based approach to AML compliance.

Investors may be categorized based on risk level, including:

• Low-risk customers
• Standard-risk customers
• High-risk customers

Higher-risk users may require enhanced due diligence procedures. Factors considered include:

• Country of residence
• Transaction patterns
• Investment volume
• Politically exposed person (PEP) status

6. Politically Exposed Persons (PEPs)

Silvaland conducts screening to determine whether a user is a Politically Exposed Person (PEP).

A PEP is an individual who holds or has held prominent public functions, including:

• Government officials
• Members of parliament
• Senior military officers
• Executives of state-owned enterprises

Additional due diligence may be required for such individuals.

7. Transaction Monitoring

Silvaland monitors transactions and investment activity to detect suspicious patterns. Monitoring may include:

• Unusual transaction sizes
• Rapid movement of funds
• Structuring transactions to avoid verification thresholds
• Suspicious investment patterns

Automated or manual review procedures may be used.

8. Suspicious Activity Reporting

If suspicious activity is detected, Silvaland may:

• Request additional information from the user
• Temporarily restrict or suspend account activity
• Report suspicious activity to relevant authorities in Latvia

Silvaland reserves the right to refuse or terminate services where illegal activity is suspected.

9. Sanctions Screening

Silvaland performs sanctions screening against international sanctions lists, including those issued by:

• the European Union
• the United Nations
• the Office of Foreign Assets Control (OFAC)

Users appearing on sanctions lists may be denied access to the platform.

10. Record Keeping

Silvaland maintains records related to customer identification and financial transactions. These records may include:

• identity verification documents
• transaction records
• compliance reviews

Records are typically retained for at least 5 to 10 years in accordance with regulatory requirements.

11. Data Protection

All personal data collected for AML/KYC purposes is processed in accordance with the GDPR and Silvaland’s privacy policy.

Personal data is stored securely and accessed only by authorized personnel.

12. Compliance Responsibility

Silvaland maintains internal procedures to ensure AML compliance. Employees and partners are required to:

• follow AML/KYC procedures
• report suspicious activity
• maintain confidentiality

Training and internal controls may be implemented to ensure compliance.

13. Refusal of Service

Silvaland reserves the right to refuse services to any user who:

• fails to complete identity verification
• provides false or misleading information
• appears on sanctions lists
• is suspected of illegal financial activity

Accounts may be suspended or terminated at Silvaland’s discretion.

14. Policy Updates

Silvaland may update this AML/KYC Policy periodically to reflect regulatory changes or operational improvements.

Updated versions will be published on the Silvaland website.