KYC / AML Policy

Last updated: 15 October 2025

To ensure full compliance with the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing of the Republic of Poland, the EU Anti-Money Laundering Directives, and internationally recognised AML/CFT standards, Meadow Link Sp. z o.o. has established and implemented a comprehensive Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Program.
This program integrates the principles of Know Your Customer (KYC), ongoing monitoring, and risk-based controls, aimed at minimising any possibility of the company being used for illicit financial purposes.

The management of Meadow Link acknowledges the critical importance of AML and CFT compliance and is fully committed to maintaining and continually improving our procedures with the highest degree of integrity, transparency, and diligence.

1. Anti-Fraud Controls and Occasional Transactions

Our platform allows users to execute occasional (one-off) transactions without the need to establish an ongoing business relationship with Meadow Link, provided that the total value of such transactions does not exceed the equivalent of EUR 1,000.

For all occasional transactions, we apply strict anti-fraud controls and basic identity screening to ensure security and prevent misuse. These measures are supported by automated systems and manual oversight designed to detect unusual or suspicious activity.

If a user exceeds the permitted transaction threshold, or if our compliance team determines that additional information is required to assess the legitimacy of a transaction, the user will be required to undergo full KYC verification.

Please note that in certain circumstances, KYC verification may be required regardless of the transaction amount—for example:

upon request from our financial or banking partners;
based on internal risk assessment;
or when there are indicators of potentially suspicious behaviour or heightened risk.

These enhanced checks help us maintain a secure and compliant operating environment.

2. Know Your Customer (KYC) Procedures

Our verification process is designed to prevent identity theft, fraud, and the misuse of our services for money laundering or terrorist financing.

To successfully complete KYC verification, users must provide accurate personal details, including their full name, residential address, and supporting identification documents. Accepted identification documents typically include:

Passport,
National ID card,
Driver’s license, or
Residence permit.

Additionally, users are required to submit proof of residence, such as a recent utility bill or bank statement, clearly showing their name and address.

Meadow Link applies a risk-based approach to verification. Depending on the risk category of the customer, product, or transaction, we may request:

information about the purpose and intended nature of the business relationship, and/or
documents evidencing the source of funds used for the transaction.

All information and documentation submitted by users undergoes both automated validation and manual review by trained compliance staff to ensure authenticity and accuracy.

3. Ongoing Monitoring and AML/CFT Controls

Meadow Link’s AML/CFT program is designed to continuously safeguard our platform against the risks of money laundering and terrorist financing.

Our designated Compliance Officers are responsible for implementing and enforcing AML/CFT measures. They apply a risk-based methodology to evaluate customers and transactions, ensuring that resources are focused on higher-risk areas.

All transactions executed on our platform are subject to automated monitoring using advanced analytical tools that detect patterns, anomalies, or behaviours associated with suspicious activity. Where an alert is triggered, the case is promptly escalated for human review by a compliance officer.

If, during the course of such an investigation, a transaction or user activity is deemed suspicious, Meadow Link reserves the right to temporarily freeze the transaction or account pending the outcome of the internal review.

Our compliance team maintains detailed logs and records of investigations, as required under the Polish AML Act, and promptly reports suspicious activities to the General Inspector of Financial Information (GIIF) or other competent authorities where necessary.

4. Sanctions and Prohibited Users

Meadow Link strictly prohibits providing services to any individual or legal entity that is:

Included in the Polish Sanctions list published by the Polish Ministry of Internal Affairs (MSWiA) and international sanctions lists, such as those issued by the United Nations (UN), the European Union (EU), or the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury; or
otherwise subject to trade restrictions, asset freezes, or embargoes.

Additionally, users who fail or refuse to provide sufficient information for verification, or whose activities raise justified suspicion, may be denied access to our services or have their transactions suspended.

5. Data Protection and Confidentiality

All customer data collected during the KYC and AML procedures is handled in accordance with the Meadow Link Privacy Policy and applicable data protection legislation, including the EU General Data Protection Regulation (GDPR).
Information is used solely for compliance and operational purposes and is stored securely, with access strictly limited to authorised personnel.

Meadow Link implements appropriate technical and organisational measures to ensure that personal data remains confidential, accurate, and protected against unauthorised access, loss, or alteration.