Introduction

This AML and KYC Policy explains why Evolution Ltd must collect certain information from you, how we verify your identity, and how we monitor activity on your account. These requirements are part of European anti-money laundering and counter-terrorist financing (AML/CTF) laws and are mandatory for all regulated financial institutions.

By opening an account or using Evolution services, you agree to provide accurate information and cooperate fully with our compliance checks.

This document is written for customers. A separate technical AML framework exists for regulators.

1. Why We Perform AML and KYC Checks

As a licensed European credit institution, Evolution must comply with:

European AML Directives (AMLD5 and AMLD6)
Lithuanian AML legislation
EU sanctions regulations
Bank of Lithuania requirements
Financial Intelligence Unit (FIU) obligations

These laws require us to:

Verify customer identities
Understand the nature and purpose of account activity
Monitor transactions
Prevent misuse of financial services
Report suspicious behavior

We must apply these rules to all personal and business accounts.

2. Identity Verification (KYC)

To open an account, you must complete identity verification. This may include:

Government-issued ID
Selfie or biometric check
Proof of address
Date of birth
Phone number and email
Sanctions screening
PEP (politically exposed persons) checks

We may request updated information at any time, especially if your activity changes.

If verification cannot be completed, we cannot provide banking services.

3. Business Verification (KYB)

Business customers must provide information about their company structure. This may include:

Company registration documents
Directors and shareholders
Beneficial owners (UBOs)
Company address
Business description and operations
Expected transaction volumes
Source of funds

We may ask for ongoing documentation as part of enhanced due diligence.

4. Source of Funds and Source of Wealth

At times, we may ask you to explain where your funds come from. This may include:

Employment income
Business income
Investment proceeds
Savings
Asset sales
Inheritance

Documentation such as payslips, invoices, contracts, or bank statements may be required.

If you cannot provide sufficient evidence, we may restrict or close your account.

5. Transaction Monitoring

We continuously monitor account activity to detect unusual, suspicious, or prohibited behavior. Monitoring may include:

Payment patterns
Cash flows and volumes
Transfers to high-risk regions
Unusual currency activity
International flows
Crypto-related transactions
Rapid movement of funds
Multiple accounts or linked devices

Monitoring is automated and manual.
High-risk activity may prompt questions or temporary restrictions.

6. Enhanced Due Diligence (EDD)

We apply enhanced checks to customers or transactions classified as higher risk. Examples include:

Politically exposed persons (PEPs)
International transactions involving high-risk jurisdictions
Large incoming or outgoing payments
Frequent crypto activity
Businesses in high-risk sectors

EDD may require:

More detailed documents
Ongoing monitoring
Additional verification
Periodic reviews

We may decline or restrict service if EDD requirements cannot be met.

7. Sanctions Screening

We must comply with EU, UN, and national sanctions. Therefore, we screen:

Customers
Beneficial owners
Transactions
Recipients
Countries and banks involved

We cannot process payments or provide services to sanctioned individuals, entities, or jurisdictions.

If sanctions rules require it, we must freeze or block funds without prior notice.

8. Prohibited Activities

You may not use Evolution for any of the following:

Money laundering
Terrorist financing
Fraud or scams
Illegal online gambling
Unlicensed financial services
Hiding the origin of funds
Crypto mixing or tumbling services
Darknet activity
Sanctions evasion
Shell companies without legitimate activity
Selling counterfeit goods
Human trafficking or exploitation

We may close your account immediately if prohibited activity is suspected.

9. Account Freezes and Restrictions

We may temporarily restrict your account if:

We cannot verify your identity
We need more information
Unusual activity is detected
A regulator or authority requests information
Sanctions apply
We suspect fraud or criminal behavior

Restrictions may remain until the issue is resolved.

In certain cases, we may be legally prohibited from telling you the reason for the freeze.

10. Reporting Obligations

We are legally required to file suspicious activity reports with the Financial Intelligence Unit (FIU) when certain criteria are met.

We are not permitted to inform you:

That a report has been filed
That a report will be filed
That FIU or law enforcement is investigating

This is known as the “anti-tipping-off” rule.

11. Your Responsibilities

You must:

Provide accurate information
Update information when asked
Explain your transactions when requested
Follow all applicable laws
Use Evolution for lawful purposes only
Respond promptly to compliance requests

Failure to cooperate may result in account closure.

12. Our Responsibilities

We must:

Identify and monitor customers
Apply risk-based AML policies
Protect the financial system
Report suspicious activity
Maintain audit logs
Train staff in AML requirements
Comply with regulators

We treat your information confidentially except where disclosure is required by law.

13. Data Protection

We process your information according to GDPR and the Evolution Privacy Policy.

AML laws may require us to retain certain data for extended periods, even after your account is closed.

14. Changes to This Policy

We may update this Policy to comply with:

Regulatory changes
Guidance from authorities
Industry standards

If updates materially affect you, we will inform you where required by law.

15. Contact Information

If you have questions about this AML and KYC Policy, you can contact:

Evolution Ltd
[Registered Address]
[Support Email]
[Website]