Pollsar Anti-Money Laundering (AML) Policy

Effective date: July 1, 2026

1. General Provisions

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

1.2. The AML Policy applies to all users of the Platform, including respondents and survey authors (hereinafter — "Authors"), and is part of the Public Offer, the User Agreement, and the Privacy Policy.

1.3. Pollsar undertakes to comply with international standards, including the recommendations of the FATF (Financial Action Task Force), as well as applicable laws, such as the General Data Protection Regulation (GDPR, EU) and the California Consumer Privacy Act (CCPA, USA).

1.4. The purpose of the AML Policy is to ensure the detection 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 crime.

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 activity.

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

2.4. KYC (Know Your Customer): The procedure for verifying the User's identity to prevent illegal activity.

2.5. PEP (Politically Exposed Person): A politically exposed person who may pose a heightened risk due to their position.

3. AML Risk Management

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

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

3.2. To reduce risks, we apply Enhanced Due Diligence (EDD) for high-risk users, including:

• Requesting additional documents confirming 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) who oversees 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 keep it aligned with current legal requirements.

4.2. KYC Procedures

4.2.1. For Authors using the paid services of the Platform, Pollsar conducts a KYC procedure that includes:

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

4.2.2. Pollsar screens Users against sanctions lists, lists of politically exposed persons (PEPs), and other databases related to financial crime.

4.2.3. When an established transaction threshold is exceeded (e.g., 10,000 USD per month), Pollsar may request additional data to verify the source of funds.

4.3. Transaction Monitoring

4.3.1. Pollsar monitors the financial transactions of Authors, including:

• Payments for subscriptions and other paid services.
• The frequency and volume of transactions, in order to identify unusual activity.

4.3.2. Suspicious transactions, such as multiple payments from different sources without a clear purpose or a mismatch between the User's activity and their declared profile, are referred to the responsible officer for analysis.

4.4. Reporting Suspicious Transactions

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

4.4.2. Pollsar may suspend the User's access to the Platform until the investigation is completed.

5. Staff Training

5.1. Pollsar conducts regular training for employees who work with User data or financial transactions on AML matters, including:

• Recognizing suspicious transactions.
• KYC and monitoring procedures.
• Obligations to report suspicious activity.

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

6. Record Keeping

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

6.2. The data includes:

• Information provided as part of 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 of compliance with the AML Policy at least once a year.

7.2. The audit results are provided to the responsible officer for analysis and for remedying identified deficiencies.

7.3. We provide annual reports on AML measures to regulatory authorities where required by law.

8. Restrictions and Sanctions for Violations

8.1. Pollsar has the right to refuse services or terminate the contract with a User if:

• The User refuses to provide data for KYC.
• The User is linked to suspicious activity, including money laundering or terrorist financing.
• The User is on sanctions lists or is a PEP without providing additional data for verification.
• The User uses the Platform to promote illegal content (e.g., through surveys or uploaded materials).

8.2. If violations are detected, Pollsar may:

• Suspend or block the User's account.
• Withhold funds related to the suspicious transaction until the investigation is completed.
• Transfer the User's data to regulatory authorities.

8.3. Pollsar is not liable for losses arising from the suspension of access to the Platform due to suspicions of illegal activity.

9. Cooperation with Regulatory Authorities

9.1. Pollsar undertakes to cooperate with regulatory authorities and to provide information about Users and transactions upon request, where required by law.

9.2. We may disclose User data to law enforcement authorities in the event of an investigation into financial crime.

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 indicated.

10.2. We will notify Users of significant changes by email or through a notice on the Platform 30 days before they take effect.

11. Contact Information

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