MIRITSOFTWARE HOUSE

MIRIT SOFTWARE HOUSE

AML & KYC Policy

Last updated: 06.11.2026

MIRIT SOFTWARE HOUSE Sp. z o.o. is committed to preventing money laundering and terrorist financing. This policy reflects the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, EU Directive 2015/849 (as amended) and applicable EU and UN sanctions regimes.

1. Purpose and scope

  • This policy applies to all clients, partners and suppliers and to every employee and contractor of the company. It sets out how we identify clients, assess risk and prevent our services from being used for illegal purposes.

2. Know Your Customer (KYC)

  • Before starting cooperation we verify the client's identity: company name, registration number, tax ID, registered address and an extract from the relevant company register.
  • We identify persons authorised to represent the client and verify their identity documents when required.
  • We identify the ultimate beneficial owner(s) (UBO) holding more than 25% of shares or control, including verification in the Central Register of Beneficial Owners (CRBR) or equivalent registers.
  • We establish the purpose and intended nature of the business relationship.

3. Sanctions and PEP screening

  • Clients, representatives and beneficial owners are screened against EU, UN, UK and OFAC sanctions lists and the Polish list of persons subject to restrictive measures.
  • We check whether a person is a Politically Exposed Person (PEP) and apply enhanced due diligence where applicable.
  • We do not cooperate with entities from jurisdictions subject to comprehensive sanctions or identified as high-risk third countries by the European Commission without enhanced due diligence.

4. Risk-based approach

  • Each client is assigned a risk level (low, standard, high) based on country, industry, ownership structure, transaction size and payment method.
  • High-risk clients are subject to enhanced due diligence, including source of funds verification and management approval.

5. Payment rules

  • We accept payments only by bank transfer from an account held in the name of the contracting client.
  • We do not accept cash payments, cryptocurrencies, prepaid cards or payments from third parties.
  • Refunds are made only to the account from which the payment was received.

6. Ongoing monitoring

  • We monitor the business relationship and transactions on an ongoing basis and update client information periodically and whenever circumstances change.

7. Reporting suspicious activity

  • Where there is a suspicion of money laundering or terrorist financing, we suspend the transaction and notify the General Inspector of Financial Information (GIIF) and, where appropriate, the competent prosecutor, as required by law. Clients are not informed of such reports (tipping-off prohibition).

8. Record keeping

  • KYC documentation and transaction records are kept for 5 years from the end of the business relationship, in accordance with the AML Act and GDPR.

9. Refusal of service

  • We reserve the right to refuse or terminate cooperation if a client does not provide the required information, if the information is inconsistent, or if the risk cannot be adequately mitigated.

10. Responsibility and training

  • The Management Board appoints a person responsible for AML compliance. Employees receive regular AML training. AML-related questions can be sent to info@mirit-soft.com.