Legal Expert

● Maintained compliance and AML framework; ● Presented regular MI to the Board of Directors; ● Carried relevant investigations, where required; ● Assessed the suitability of third-party providers for financial services; ● Reviewed complex KYC/KYB and onboarding cases; ● Provided guidance on Compliance and AML matters across the business; ● Ensured upcoming products were within the regulatory perimeter; ● Maintained the company’s UK, EU and LT AML/CTF and sanctions policies and procedures. Wrote, developed and revised policies, procedures, processes and internal controls to ensure proper governance. Ensured that all compliance policies and procedures are kept up-to-date; ● Conducted UK, EU and LT AML/CTF and sanctions risk assessments, including quality assurance checks and assessment of new products, services and business initiatives; ● Investigated and provided analysis of any suspicious transactions following AML regulations and made all appropriate suspicious transaction reporting (CTR) to Lithuanian FCIS; ● Delivered AML/CTF and sanctions training; ● Reported duties to the Managing Directors, the Board of Directors, the head office and the relevant stakeholders regarding progress on business goals. Escalated to management any regulatory and/or official external body-related issues where necessary; ● Served as the on-site resource for regulatory and external body queries and responses; ● Provided advice on UK, EU and LT AML/CTF and sanctions matters to product, operations and business colleagues; ● Worked closely with lawyers, regulators and other counterparties to meet the regulatory requirements for Lithuanian Deposit Virtual Currency Wallet Operator and Virtual Currency Exchange Operator (“VASP”) and related registrations and/or licenses. Also liaised with internal and external auditors and regulators to ensure that all requests and any issues were addressed in a timely and accurate manner; ● Substituted daily duties and took responsibilities from other MLROs, Head of Compliance, and Head of Risk. Substituted COO and Directors for their everyday role duties/tasks and company-leading matters; ● Ensured that Vaultoro has adequate systems and controls according to each regional regulation, where Vaultoro is present; ● Tracked UK, EU and LT regulations and implemented them into the company/company’s system myself and/or created implementation plans for developers’ team (MiCA, Travel rule in Crypto); ● Completed training: GDPR, Wind-down planning.

● Promoted from TMS (Transaction Monitoring System) analyst to Escalations and Subpoenas analyst 2 months after the start of work; ● Reviewed an escalated alert with the deep investigation to analyse the alert for unusual activity to file a SAR or to clear, followed by SARs and STRs fillings, preparation of documents and evidence for judicial authorities - NCA and Gardai; ● Dis-positioned and fully documented all alerts, including supporting data, analysis and rationale for disposition, within a timely manner. Updated customer data with their uploaded documents into the system. Reviewed and analysed blockchain transactions to assess reasonable causes to escalate or clear the alert or escalated by identifying suspicious activity on blockchain & reviewing negative news, OFAC, red flags, and due diligence findings; ● Shadowing and quality control sessions for other employees; ● Team lead’s substitution on daily duties; ● Completed training: AML, Fraud, Compliance, BSA, Red flags, Blockchain, Cryptocurrencies, Transaction Monitoring, NFT, and Anti-bribery.