Anti-Money Laundering (AML) & KYC Policy

1. Purpose and legal framework

Kalamora sp. z o.o. (KRS 0001159962, NIP 1231576002) is committed to preventing money laundering, terrorist financing and sanctions evasion. This policy follows the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, EU Directives 2015/849 (AMLD4) and 2018/843 (AMLD5), Regulation (EU) 2024/1624, and EU, UN, UK and US (OFAC) sanctions regimes.

2. Zero tolerance

We do not enter into or continue business relationships connected with money laundering, terrorist financing, corruption, fraud, tax evasion or sanctioned persons, countries or activities.

3. Know Your Customer (KYC)

Before starting a project we may request:

• Full legal name, registered address and registration number of the company.
• Tax / VAT identification number.
• Identity of the persons authorised to represent the company.
• Identity of the ultimate beneficial owners (UBO, more than 25% ownership or control), verified e.g. via the Central Register of Beneficial Owners (CRBR).
• Purpose and intended nature of the business relationship and source of funds where justified.

4. Risk-based approach

Each client is assessed for risk based on country, sector, ownership structure, payment method and project type. Enhanced due diligence applies to politically exposed persons (PEPs), complex ownership structures and high-risk third countries listed by the European Commission or FATF.

5. Sanctions screening

Clients, their representatives and beneficial owners are screened against EU consolidated sanctions lists, UN Security Council lists, the Polish list of the Ministry of Interior and Administration, UK HMT and US OFAC lists. We do not work with persons or entities subject to sanctions, nor with clients from comprehensively sanctioned jurisdictions.

6. Payments

• Payments are accepted only by bank transfer from an account held in the client's name.
• No cash, anonymous payments or crypto-asset payments.
• No payments from or refunds to unrelated third parties.

7. Ongoing monitoring

We monitor business relationships throughout their duration and update client information when circumstances change. Unusual or suspicious activity is reviewed internally.

8. Reporting

Where required by law, suspicious transactions are reported to the General Inspector of Financial Information (GIIF) and relevant authorities. We may refuse, suspend or terminate a relationship without explanation where AML concerns arise.

9. Record keeping

KYC documents and transaction records are kept for 5 years from the end of the business relationship, then securely deleted, in line with the GDPR.

10. Responsibility and training

Management designates a person responsible for AML compliance. Staff receive regular AML and sanctions training. This policy is reviewed at least once a year.

11. Contact

AML questions or reports: info@ka1a-mora.com.