Pollsar Anti-Money Laundering (AML) Policy

Effective Date: April 27, 2025

1. General Provisions

1.1. This Anti-Money Laundering Policy (hereinafter "AML Policy") has been developed by POLLSAR LLC (hereinafter "Pollsar", "we"), a company registered in the United States of America (Florida), to prevent the use of the Pollsar platform (hereinafter "Platform"), available at https://pollsar.com, for money laundering, terrorist financing, or other illegal financial activities.

1.2. The AML Policy applies to all users of the Platform, including respondents and creators (also referred to as "makers"), and forms part of the Public Offer, Terms of Use, and Privacy Policy.

1.3. Pollsar is committed to complying with international standards, including the recommendations of the Financial Action Task Force (FATF), as well as applicable laws such as the General Data Protection Regulation (GDPR, EU), the California Consumer Privacy Act (CCPA, USA), and Federal Law No. 152-FZ "On Personal Data" (Russia).

1.4. The purpose of this AML Policy is to ensure the identification and prevention of suspicious transactions related to money laundering, terrorist financing, or other illegal activities, and to protect the Platform and its users from financial crimes.

2. Definitions

2.1. Money Laundering: The process by which illegally obtained funds are disguised as legitimate income.

2.2. Terrorist Financing: The use of funds to support terrorist activities.

2.3. Suspicious Transaction: Any financial transaction that raises suspicion due to its nature, amount, frequency, or inconsistency with the user's typical activity.

2.4. KYC (Know Your Customer): The procedure for verifying a user's identity to prevent illegal activities.

2.5. PEP (Politically Exposed Person): An individual who may pose a higher risk due to their political position or influence.

3. AML Risk Management

3.1. Pollsar conducts regular assessments of risks related to money laundering and terrorist financing based on:

• User geography (e.g., high-risk jurisdictions).
• Nature of transactions (e.g., frequency and volume of payments for subscriptions or other services).
• Type of users (e.g., PEPs, high-risk users).

3.2. To mitigate risks, we implement Enhanced Due Diligence (EDD) measures for high-risk users, including:

• Requesting additional documents to verify the source of funds.
• Analyzing transactions for suspicious activity.

4. Measures to Prevent Money Laundering

4.1. Appointment of a Responsible Officer

4.1.1. Pollsar appoints a responsible officer (AML Compliance Officer) to oversee the implementation of the AML Policy, including transaction monitoring, staff training, and interaction with regulatory authorities.

4.1.2. The responsible officer is required to regularly review the AML Policy to ensure compliance with current legal requirements.

4.2. KYC Procedures

4.2.1. For creators using paid services on the Platform, Pollsar conducts KYC procedures, which include:

• Identity verification (providing name, email address, and, if necessary, identity documents).
• Verification of billing information (e.g., organization details, address).

4.2.2. For respondents undergoing verification to increase their trust level, Pollsar collects their name and location, and temporarily requests document photos (deleted immediately after verification).

4.2.3. Pollsar checks users against sanctions lists, PEPs, and other databases related to financial crimes.

4.2.4. If transactions exceed a certain threshold (e.g., 10,000 USD per month), Pollsar may request additional information to verify the source of funds.

4.3. Transaction Monitoring

4.3.1. Pollsar monitors creators' financial transactions, including:

• Payments for subscriptions and access to the Pollsar Audience.
• Payments for advertising placements (based on the number of clicks).
• Frequency and volume of transactions to identify unusual activity.

4.3.2. Suspicious transactions, such as multiple payments from different sources without a clear purpose or inconsistencies with the user’s stated profile, are forwarded to the responsible officer for analysis.

4.4. Reporting Suspicious Transactions

4.4.1. If Pollsar identifies a suspicious transaction, we are obliged to report it to the relevant regulatory authorities (e.g., FinCEN in the USA, Rosfinmonitoring in Russia), if required by law.

4.4.2. Pollsar may suspend a user’s access to the Platform pending the completion of an investigation.

5. Staff Training

5.1. Pollsar conducts regular training for employees handling user data or financial transactions on AML matters, including:

• Recognizing suspicious transactions.
• KYC and monitoring procedures.
• Responsibilities for reporting suspicious activities.

5.2. Training is conducted at least once a year or upon changes in legislation.

6. Record Keeping

6.1. Pollsar retains records related to KYC procedures and transactions for a period of 5 years from the date of their creation to comply with legal requirements.

6.2. These records include:

• Information provided during KYC (e.g., verification data).
• Transaction details (amount, date, payment method).
• Reports on suspicious transactions (if any).

6.3. After 5 years, the data is deleted or anonymized unless otherwise required by law.

7. Audit and Reporting

7.1. Pollsar conducts internal audits to ensure compliance with the AML Policy at least once a year.

7.2. Audit results are submitted to the responsible officer for analysis and resolution of identified issues.

7.3. We provide annual AML compliance reports to regulatory authorities, if required by law.

8. Restrictions and Sanctions for Violations

8.1. Pollsar reserves the right to deny service or terminate a user’s contract if:

• The user refuses to provide KYC information.
• The user is involved in suspicious activities, including money laundering or terrorist financing.
• The user is listed on sanctions lists or identified as a PEP without providing additional verification data.
• The user uses the Platform to promote illegal content (e.g., through surveys or advertisements).

8.2. In case of violations, Pollsar may:

• Suspend or block the user’s account.
• Withhold funds related to a suspicious transaction pending investigation.
• Disclose user data to regulatory authorities.

8.3. Pollsar is not liable for losses resulting from the suspension of access to the Platform due to suspected illegal activities.

9. Cooperation with Regulatory Authorities

9.1. Pollsar is committed to cooperating with regulatory authorities and providing user and transaction information upon request, if required by law.

9.2. We may disclose user data to law enforcement agencies in the event of investigations into financial crimes.

10. Changes to the AML Policy

10.1. Pollsar may update the AML Policy due to changes in legislation or operational activities. The updated version will be published on the Platform with the effective date.

10.2. We will notify users of significant changes via email or through a Platform notification at least 30 days before the changes take effect.

11. Contact Information

If you have any questions or requests related to this AML Policy, please contact us:
Email: [email protected]
We will respond within 30 days of receiving your request.