AML Policy




1. These Rules for The Prevention of Money Laundering and (or) Terrorist Financing (hereinafter – the Rules) are prepared to ensure the prevention of money laundering and terrorist financing in activity of Mirhax Group UAB (hereinafter – the Company). 

2. The Rules describe how the Company will organize and ensure the adequate anti-money laundering and counter terrorism financing procedures. The implementation of the Rules will ensure that the name, reputation and financial integrity of the Company, whilst ensuring compliance with all necessary laws and regulations. 

3. The provisions of the Rules must be adhered to by all operations, organization and staff of the Company. 

4. The Rules are prepared in accordance with the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania (hereinafter – the Law) and other applicable legal acts of the Republic of Lithuania. 

5. Unless the Rules state otherwise, all terms used therein have the meaning indicated in the Law and other applicable legal acts. 


1. Unless otherwise required by the context, the following terms beginning in a capital letter shall be taken to have the following definitions: 

1.1. Customer – a legal or natural person performing monetary operations or concluding transactions with the Company; 

1.2. Company – Mirhax Group UAB, legal entity code 305771191, registered address at Vilkpėdės g. 22, Vilnius, Republic of Lithuania;

1.3. Responsible Employee – an employee appointed by the CEO who is responsible for the implementation of measures for the prevention of money laundering and (or) terrorist financing in accordance with the Rules; 

1.4. Prominent Public Functions – functions which are listed in Article 19(2) of the Law or are included on the list of prominent public functions published by the FCIS; 

1.5. Close Family Member – spouse, a person with whom a civil partnership is registered, parents, siblings, children and spouses or civil partners of children;

1.6. Business relationship – a business, professional or commercial relationship between a Customer and the Company which is connected with their professional activities and which is expected, at the time when the contact is established, to have anelement of duration. 2

1.7. Beneficial Owner – a natural person, who is the owner of a Customer (a legal person) or controls the Customer, and/or a natural person for the benefit of which a transaction or activity is being conducted. The Beneficial Owner is considered to be

a) In a legal person: 

(i) a natural person who owns the legal person or who controls it either directly or indirectly by owning a sufficient percentage of the legal person’s shares or voting rights, including bearer shares and control through other means, other than a company listed on a regulated market that is subject to disclosure requirements consistent with EU law or subject to equivalent international standards which ensure adequate transparency of ownership information; 

(ii) a natural person holding 25 % plus one share or an ownership interest of more than 25% in the legal person is considered to be a direct owner. A natural person holding 25 % plus one share or an ownership interest of more than 25 % in a legal entity or entities which control or hold 25 % plus one share or an ownership interest of more than 25 % in a legal entity is considered to be an indirect owner; 

(iii)a natural person performing the role of the senior manager if the person in point (i) above cannot be determined or there are doubts on whether the person determined is the Beneficial Owner; 

b) in the case of trusts: 

(i) the settlor; 

(ii) the trustee(s); 

(iii)the protector, if any 

(iv)the beneficiaries, or where the individuals benefiting from the legal arrangement or entity have yet to be determined, the class of persons in whose main interest the legal arrangement or entity is set up or operates; 

(v) any other natural person exercising ultimate control over the trust by means of direct or indirect ownership or by other means; 

c) in the case of legal entities such as foundations, and legal arrangements similar to trusts, the natural person(s) holding equivalent or similar positions to those referred to in point (b); 

1.8. EU Member State – a member state of the European Union or the European Economic Area; 

1.9. Third Country – a country which is not a member state of the European Union or the European Economic Area; 

1.10. FCIS – The Financial Crime Investigation Services under the Ministry of the Interior of the Republic of Lithuania; 

1.11. Politically Exposed Person (PEP) – a natural person who is carrying out or has carried out Prominent Public Functions, their Close Family Members and Close Associates. A person who has not carried out Prominent Public Functions during at least the last year by the date of entering the Business relationship or making of a transaction or such a person’s Close Family Members or Close Associate are not considered as politically exposed persons; 

1.12. Suspicious Financial Operation – a monetary transaction, which is performed with funds, which are suspected to have been received (either directly or indirectly) from criminal activities or from participating in such activities or/and are related to terrorist financing; 

1.13. Close Associates – natural persons who are known to have joint Beneficial Ownership of legal entities or legal arrangements, or any other close business relations, with a Politically exposed person and (or) natural persons who have sole Beneficial Ownership of a legal entity 


or legal arrangement which is known to have been set up for the de facto benefit of a Politically exposed person

1.14. Virtual Currency – an instrument with a digital value but no legal currency or monetary status, which is not authorized or guaranteed by a central bank or other public authority and which is not necessarily pegged to currency but which is recognized by natural or legal persons as an exchange instrument and which is transferable and sold electronically; 

1.15. Virtual Wallet – public key addresses which are generated for virtual currency addresses for the storage and management of virtual currencies entrusted to other natural or legal persons (third parties) but remaining in their ownership. 


1. The Company takes all necessary, proportionate measures in order to identify its Customer and to verify the identity of the Customer and Customer’s Beneficial Owners. The Company takes measures and determine identity of the Customer or his representative in the following cases: 

1.1. before establishing a Business relationship; 

1.2. before conducting one or several related Virtual Currency transactions (exchanges) or allowing a deposit of Virtual Currency on a Virtual Wallet the value of which is equal to or exceeds EUR 1,000 at the time of the transaction and/or deposit; 

1.3. if there is suspicion that information previously provided about the Customer or his representative is incorrect and/or incomplete; 

1.4. in any other case, when there are suspicions that an act of money laundering and / or terrorist financing is, was or will be carried out. 

2. The Company establishes Customer’s identity only remotely, i. e. when the Customer is not physically present. 

Remote Customer identification 

3. The Company establishes Customer’s (natural person’s or legal person representative’s) identity remotely by using the following measures: 

3.1. when using information from third parties about the Customer or the beneficial owner in accordance with the procedure laid down in the Law; 

3.2. when information about the Customer’s identity is confirmed with a qualified electronic signature supported by a qualified certificate for electronic signature which conforms to the requirements of Regulation (EU) No 910/2014; 

3.3. when using electronic means allowing direct video streaming in one of the following ways: 

a) the original of the identity document or an equivalent residence permit in the Republic of Lithuania is recorded at the time of direct video streaming and the identity of the Customer is validated using at least an advanced electronic signature which conforms to the requirements laid down in Regulation (EU) No 910/2014; 

b) the facial image of the Customer and the original of the identity document or an equivalent residence permit in the Republic of Lithuania shown by the Customer is recorded at the time of direct video streaming. 

4. In every case establishing Customer’s identity remotely by using measures specified in paragraph 9 is allowed only when there are all conditions laid down in the Law. 

5. When establishing Customer’s identity remotely, the Company shall: 

5.1. verify whether there are any circumstances to apply enhanced Customer due diligence. If such circumstances are present the procedures for enhanced Cust


Laisves Ave.60 Vilnius. Lithuania 05120


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