MISTERTANGO, UAB, INNER CONDUCT ORDER TO IMPLEMENT

MONEY LAUNDERING AND TERRORIST FINANCING PREVENTIVE MEASURES

2014

Content
Content
I. General Provisions
II. Features and limitations of the provided services
III. Legal acts that set money laundering and (or) terrorist financing preventive measures and
liability for the breaches of the legal acts
IV. Rules on identifying the clients and beneficiaries identities, and money transactions that are
linked together
IV.1 Identifying the clients identity
IV.2 Identifying the beneficiarys identity
IV.3 Monitoring of the clients business relations
V. Identifying, terminating and informing the FCIS on the suspicious monetary operations
VI. Final provisions
VII. Annexes

INNER CONDUCT ORDER TO IMPLEMENT MONEY LAUNDERING AND TERRORIST

FINANCING PREVENTIVE MEASURES
COMPANY
Title:

MisterTango, UAB

Company code:

303262295

Office:
Vilnius

Veiveriu street, 9B-1, LT11346, Municipality of Vilnius city,

Register, the Companys

data is accumulated and
stored at:

Register of the Legal Entities

This inner conduct

order is approved by: /signed/
APPROVED:

General Director
(position)
Audrius Ramanauskas
(name, surname, signature, date)
15 (fifteen)
(number of pages in words and digits)

I. General provisions
1. This Order is prepared to prevent from money laundering and (or) terrorists financing.
2. Intended purpose to set MisterTango, UAB, (herein the Company) order of prevention
of money laundering and (or) terrorists financing in order to implement the legal acts
requirements.
3. The definitions, used in the Instructions shall be the same as of the Law on money laundering
and (or) terrorists financing prevention of the Republic of Lithuania (Zin., 1997, No. 64-1502;
2008, No. 10-335) (herein MLTFP).
4. Companys risk of money laundering and (or) terrorists financing is detected according the
professional competence and this Order criteria.
II. Features and limitations of the provided services
5. The services, which the Company plans to provide: e-purse, integration of e-shops payments
and advertising the e-shops. The latter are not financial services, so they are not regulated by the
laws on e-money and e-money entities.
6. A planned e-purse service shall feature:
6.1 Registered users shall have a possibility to receive money to their e-purse account from other
users, their own bank accounts or the bank account of other persons.
6.2 Registered users shall have a possibility to transfer money from their e-purse account to other
registered users (internal transfers) and to the customers of the Bank of Lithuania (external
transfers).
6.3 In order to perform an external transfer (i.e. to transfer to the unregistered user to his/her
bank account), the sender is to be identified; in case of a transfer between the identified
customers, the repeated check shall not be performed ( the sufficient fact that the users are
registered and logged in to the system).
6.4 Registered users shall have a possibility to send applications to pay the invoices for other epurse users.
6.5 All transactions are performed electronically; there shall be no transactions at the natural
branches.
6.6 Electronic copies of all related documents are accumulated at the Companies servers; there
shall be no paper copies of the mentioned documents.
7. E-purse service shall have the following limitations:
7. Cash transactions shall not be performed ( e-purse funds could not be in cash; the funds could
be put or taken from the bank account only).
7.2 A sum of transactions of one user for one day shall not exceed 10 000 (ten thousand euros) or
the equivalent sum in a foreign currency, except the activities, laid down in art. 17 p. 7 of the
Law on the MLTFP.
7.3 The service user could become ones, possessing a bank account at a bank of the EU.
7.4 E-storage devices are not allowed to store the e-money.
7.5 Credit provision services shall not be provided.
III. Legal acts that set money laundering and (or) terrorist financing preventive measures and
liability for the breaches of the legal acts
8. Law on the MLTFP;
9. Criminal Code of the Republic of Lithuania (Zin., 2000, No. 89-2741);
10. the Code of Administrative Infringements (Zin., 1985, No. 1-1) (art. 173, 224 14 and 2591),
setting an administrative liability for the breaches of the money laundering prevention legal acts,

also the officers, eligible to fill the protocols and the institutions, hearing the administrative
cases;
11. 24 September, 2008 Decision No. 942 of the Government of the Republic of Lithuania On
setting the presentation order of the a list of criteria that are applying for the customer being of a
small money laundering and (or) terrorist financing risk and criteria that are applying for the
customer being of a high money laundering and (or) terrorist financing risk; on approving the
rules of identifying the clients and beneficiaries identities, and money transactions that are
linked together and the information on detected features of a possible money laundering and (or)
terrorist financing ; on beaches of the Law on money laundering and (or) terrorist financing
prevention of the Republic of Lithuania and on anti-criminal measures (Zin., 2008, No. 1144348).
12. 5 June, 2008 Decision No. 562 of the Government of the Republic of Lithuania On
approving the setting of the criteria on the customers performed monetary operations,
extraordinary and suspicious operations and transaction register books arrangement rules and on
setting the criterion defining the customers activity, featuring high permanent and regular
monetary operations (Zin., 2008, No. 70-2653);
13. 9 July, 2008 Decision No. 677 of the Government of the Republic of Lithuania On
approving the description order of a list of criteria on the customers performed monetary
operations or transactions to be considered as extraordinary and suspicious and the termination
of the extraordinary and suspicious monetary operations or transactions and the information on
the extraordinary and suspicious monetary operations or transactions submission to the Financial
Crime Investigation Service at the Ministry of Interior (Zin., 2008, No. 82-3256).
IV Rules on identifying the clients and beneficiaries identities, and money transactions that are
linked together
IV.1 Identifying the clients identity
14. The Company shall take all appropriate directed and proportional measures in order to set
whether a customer acts on his/her own behalf or is controlled and to set/check identification:
14.1 of a customer (a natural person or a legal entity), performing monetary operations or
concluding transactions;
14.2 of a beneficiary (a natural person who is an owner of a customer ( legal entity or a foreign
company) or controls the customer, and (or) a natural person, on whose behalf the transaction or
the activity was performed), who benefits from different monetary operations or transactions.
15. The Company shall take all measures to set and to check the customers and the beneficiarys
identity in following cases:
15.1 Before starting business relations;
15.2 in case of doubts of the previously received customers and the beneficiarys identity data
authenticity or legality,;
15.3 in any other cases of suspicion of a previous, current or future money laundering and (or)
terrorists financing deed acts, regardless of a sum of a monetary operation or other exemptions.
16. The Companys personnel must not:
16.1 perform operations, defined in art. IV.15 of this Order in case the Instructions regulates that
the Customer:
16.1.1 fails to submit personal data identification evidence;
16.1.2 submits partial or incorrect data and the Company is aware of this;
16.1.3 avoids submitting personal identification data;
16.1.4 hides beneficiarys identification data;

16.1.5 avoids submitting or fails to submit information to identify beneficiarys identity, or the
submitted data is not sufficient;
16.2 To perform monetary operations without customers personal data identification documents
or in case a reasonable suspicion that the presented documents are fraudulent.
17. By identifying the customers identity the personnel of the Company ask the customer to
submit documents with his/her personal data, and performs the following:
17.1 assesses whether a customer a natural person, who starts to cooperate with the Company,
submits valid personal identification documents or the equivalent travel documents; sets whether
the submitted document contains the customers photo;
17.2 assesses the state of a presented document ( focusing on whether the photo or the pages
were nor replaced, corrected, etc.);
17.3 clarifies whether a customer a natural person or a legal entity shall use the services
him/her/itself or represents another person;
17.4 clarifies whether a customer a natural person or a legal entity possesses necessary
attorneys to act on behalf of another person;
17.5 copies the page with a photo of a natural persons personal identification document or scans
the document;
17.6 identifying the foreign customer copies the page with a photo of personal identification
document or travel document or scans the document;
17.7 as laid down in the Companys disciplinary rules takes measures to ground the necessity of
application the simplified or the enforced personal identification.
18. By registering a new natural person, whose identify has been already set by the bank, acting
in the Republic of Lithuania or a person, who is identified with a qualified e-signature, the
personnel of the Company ask the following:
18.1 given name (-s);
18.2 surname (-s);
18.3 personal ID code or other appointed unique combination to identify the person;
18.4 bank account number and title of a bank;
19. By identifying the customers identity the personnel of the Company ask the customer (a
natural person) to submit documents or copies with the following data that confirm the identity:
19.1 in case of the citizen of the Republic of Lithuania:
19.1.1 given name (-s);
19.1.2 surname (-s);
19.1.3 personal code;
19.1.4 photo;
19.1.5 signature;
19.2 in case of the foreign citizen:
19.2.1 given name (-s);
19.2.2 surname (-s);
19.2.3 date of birth ( if applied- personal code or other unique combination of symbols,
appointed to this persons identification);
19.2.4 number, place of issuance, expiry date of the ID or travel document, or the permission on
permanent residence in a foreign state (applied for the foreigners who reside in foreign states
permanently);
19.2.5 photo;
19.2.6 signature.

20. By registering a new natural person, whose identify has been already set by the bank, acting
in the Republic of Lithuania, meeting the Law on MLTFP requirements and has signed an
agreement to submit the Company customers ID data (copies of personal identification
documents), shall ask the customers to submit the following:
20.1 title;
20.2 legal form, office;
20.3 codes, in case of any;
20.4 bank account number and title of the bank;
21. By identifying the customers identity the personnel of the Company ask the customer (a
legal entity) to submit documents or copies with the following data that confirm the identity:
21.1 title;
21.2 legal form, office;
21.3 code in case of any;
21.4 registration extract and its issuance date;
21.5 representatives, acting on behalf of a legal entity (data, laid down in art. 19.1 and 19.2 of the
Instructions);
21.6 types of activities, object and purposes of business and type of commercial economic
activity of a legal entity.
22. In case the customers personal data has been accumulated at identify has been already set by
the bank, acting in the Republic of Lithuania, meeting the Law on MLTFP requirements and has
signed an agreement to submit the Company customers ID data (copies of personal
identification documents),a new customer shall be registered only after checked whether its
submitted data meets the possessed by a bank (additional identification check: a customer
performs a control transfer from the bank account, defined when registered; in case the transfer
data (name, surname, bank account number unique systems generated ID code) are the same as
defined when registered, the additional check is considered to be implemented).
23. In case a monetary operation or a transaction has been performed by a representative, the
required data shall be identified for the both: the principal and the attorney.
24. In case the confirmation of the identity has been performed at physical absence of a
customer, the identity shall be set with the originals or the copies of the latter, approved by a
notary public. The documents in foreign languages are accepted with a notary mark, verifying
the authenticity of the translation.
25. Each customers identification or travel document (in case of a material copy) shall be
marked with a authenticity mark, including words copy is true, also the position, signature,
name and surname, date and stamp of the authorized person.
26. The Companys personnel use two customers identification ways, as laid down in the Law
on MLTFP according to the Order:
26.1 simplified;
26.2 enforced.
27. The simplified procedure is applied for:
27.1 the companies, which stock papers are allowed to be traded on one or several EU member
states markets and other foreign companies which stock papers are allowed to be traded on
regulated markets and required to reveal information on their activities by the EU regulation;
27.2 general accounts, managed by notaries and other legal service providers from the EU or the
third states for the beneficiaries in case they are governed by the money laundering and (or)
terrorists financing requirements that meet international standards and controlled by the

competent institutions, in case of the financial institutions, possessing the accounts require to
submit information on the beneficiarys identity.
27.3 in case of e-money, when e-storage devices cannot be added and the maximum sum does
not exceed 150 euros or its equivalent in a foreign currency or in case e-storage devices can be
added, but a total value of transactions during one calendar year is applied with a limit of 2 500
EUR or its equivalent in a foreign currency, except cases when during the same calendar year an
owner of e-storage device takes 1 000 EUR or its equivalent in a foreign currency, or a larger
sum;
27.4 for a customer in case it is a credit or a finance institution, governed by the Law on MLTFP,
or a credit or a finance institution, registered in other EU member state or the third state, setting
the equal requirements as in the Law on MLTFP and controlled by the competent institutions;
27.5 a customer, considered a of a small money laundering and (or) terrorist financing risk.
28. A customer, considered a of a small money laundering and (or) terrorist financing risk, is one
whose permanent place of residence or of activity is the EU member state (address of the place
of residence for the customer as a natural person or the place (state), the legal entity is
governed/controlled from, is in the EU; in case the declared place of managing bodies of a
customer as a legal entity is in the EU) and meeting the following criteria:
28.1 a customer is a public enterprise, established according to the requirements of the law on
Public Enterprises of the Republic of Lithuania (Zin., 1996, No. 68-1633; 2004, No. 25-752) or
according to the EU regulation, also wich meets the following criteria:
28.1.1 a customer is appointed with the functions according to the EU Treaty, EC Treaty or the
secondary legal acts of the EC;
28.1.2 information on the customers identity is public and its transparency is without doubt;
28.1.3 customers activity and accountancy methods are clear and understood by the Company;
28.1.4 a customer reports to the EC institution or the EU member state authority;
28.2 activity or monetary operations of a customer as a legal entity or a natural person are
performed rarely or in a very limited manner (set by a permanent monitoring) and its use money
laundering and (or) terrorist financing is of a low probability and meets one or all of the
following criteria (for a natural person and the legal entities accordingly):
28.2.1 a customer declares that he/she/it provides financial services or performs monetary
operations, but this activity is not the main and covers less than 5 percent from a total activity
turnover;
28.2.2 an activity is performed only by concluding transactions and only with a limited number
of customers with a transaction value less than 1000 euros or its equivalent in a foreign currency;
28.2.4 the main activity of a customer is not one of a financial institution or other subject, except
laid down in art. 8 p. 7 of the Law on the MLTFP.
29. Prior to performing customers identification procedure the responsible employee of the
Company checks if there are circumstances, allowing applying a simplified customer
identification procedure.
30. If the laws allow applying a simplified customer identification procedure employee of the
Company chooses the customer identification measures and their scope, defined in art. 17 of the
Instructions at his/her own consideration.
31. It is forbidden for the employees of the Company to apply a simplified customer
identification procedure in case a separate decision of the European Commission is passed.
32. An enforced customer identification procedure is applied, when:

32.1 transactions or business relations are concluded via a representative or a customer does not
participate in the personal identification procedure;
32.2 transactions or business relations are concluded with natural persons political actors;
32.3 a customer, considered of a high money laundering and (or) terrorist financing risk.
33. A customer, considered of a high money laundering and (or) terrorist financing risk, is one
who meets one of the following criteria:
33.1 a customer avoids to perform actions, necessary to identify his/her identity and to submit
information on him/her/itself or the business during the identification procedure;
33.2 upon the Companys request the customer does not submit documents, reasoning the
financial activity (documents, grounding the transactions and other financial activities
concluded/performed in past or currently, documents of incorporation);
33.3 a customer as a natural person lives in a state that is not a member of the FATF or the FATF
observer, a member of other international organization, fighting with money laundering and (or)
terrorists financing;
33.4 customers, customers representative (in case a monetary operation is performed via a
representative), the beneficiarys identification documents meets data of the Republic of
Lithuania and international organizations (FATF, the UN, the EU) lists with personal data of
ones, involved in money laundering and (or) terrorists financing or they are applied with
sanctions according to the Law on economic and other international sanctions implementation of
the Republic of Lithuania (Zin., 2001, No. 110-3992). In that case a customer has to submit
written information on the current place of residence, post address and contacts (operating tel.
numbers, e-mail addresses);
33.6 the employees of the Company detects that some unusual features of an ordinary customers
activity (more frequent settlements in cash, mo0netary operations with large sums, paying for
the products, not related with a main activity of a customer, etc.);
33.7 for a customer as a natural person age, position, financial state ( income is low in terms of
the financial activity scope) objectively does not meet the customers financial activity;
33.8 a customer belongs to a higher risk category, set according to the personal risk assessing
and management procedures.
34. Prior to implementing customers identification procedure the responsible employee of the
Company checks if there are circumstances to apply an enforced identification procedure.
35. Performing customers enforced identification procedure when the transactions or business
relations performed via representative or a customer does not participate in identification
procedure or there is a high risk of money laundering and (or) terrorist financing, the responsible
employee of the Company shall apply one or several additional measures:
35.1 to use additional identification data, documents and information;
35.2 to use additional measures in order to check or to approve submitted documents or to
require data proving documents from the financial institution;
36. Performing customers enforced identification procedure the responsible employee of the
Company shall clarify if a person is a political actor.
37. In case the transactions or business relations are performed with the natural persons who are
political actors, the responsible employee of the Company shall:
37.1 accept an approval of an authorized manager in order to start business relations;
37.2 to take appropriate measures to set a source of funds, involved in business relations;
37.3 to perform an enforced permanent monitoring of business relations with the natural persons
who are political actors.

38. In case a person terminates his/her activities as an important public actor at least for one
year, the persons, approved the level of money laundering and (or) terrorist financing , shall not
consider him/her as a political actor. The Company applies inner procedures to set if a customer
and a beneficiary are natural persons political actors: registering the natural person (or updating
the data as laid down in art. 48) is asked to submit information on activities in politics. The
person, who submits the information, is liable for its precision and legality.
39. Performing customers enforced identification procedure in case of money laundering and
(or) terrorist financing risk, the responsible employee of the Company applies art. 35 and 36 at
his/her own consideration.
40. If the employee of the Company detects that a customer submitted the personal or
beneficiarys information, known as incorrect, or hidden and there are circumstances, laid down
in art. 11 p. 1 of the Law on the MLTFP as mandatory to ally an enforced procedure, he/she shall
immediately re-identify the customer with an enforced procedure.
41. The Company detects customers or beneficiarys personal identification directly in absence
by using data of banks acting in the Republic of Lithuania and other bodies or their foreign
subsidiaries in case they meet the third party requirements, laid down in the Law on the MLTFP.
The provision is applied in case the identified financial institution has to submit the customers
identification documentation to the Company.
42. In case the party acts as the third person and meets the customers or beneficiarys
requirements, laid down in the Law on the MLTFP, the Company is allowed to ask the customer
other documents or information, required by another EU member state.
43. The Company must not use the third party from the third states information on a customer or
a beneficiary in case the European Commission has passed a decision on it.
44. The liability of implementation of identification requirements of a customer or a beneficiary,
laid down in the Instructions, is taken by the third state persons, used the information on a
customer or a beneficiary.
IV.2 Identifying the beneficiarys identity
45. In all cases of identification of the customer it is necessary to identify a beneficiary/
Identification of a beneficiary always means identification of a natural person or their group.
46. In case of an inner transfer the beneficiarys identification is set according to data, submitted
when registered.
47. During a new users (legal entities) registration the Company identifies the beneficiary as
follows:
47.1 asks the customer to submit the following data on the beneficiary (herein identification
data):
47.1.1 given name (-s);
47.1.2 surname (-s);
47.1.3 personal code or other unique combination of symbols, appointed to this persons
identification;
47.1.4 bank account number and title of the bank.
47.2 checks additionally the customers submitted data, information on beneficiary
according
to the documents, data and information, received from a reliable and independent source or in
case when the information on beneficiary is accumulated at banks of the Republic of Lithuaniatheir data.

48. The mentioned actions involve and a request for a customer to define public sources, proving
the information on a beneficiary.
49. Identifying a customer and a beneficiary it shall be grounded by documents, data or
information which is public or received from a reliable and independent source, also databases,
other subjects or financial institutions references, etc.
IV.3 Monitoring of the clients business relations
50. The Company is performing a permanent monitoring of customers business relations,
including research on transactions, concluded during the relations, in order to insure that the
transactions meet knowledge on customer, his/her/its business (type, business partners, territory,
etc.) and type of risk, also a source of funds upon the necessity (eg. in case of an unclear legal
ground of an operation, in case a monetary operation does not reflect customers financial state,
etc.).
51. Monitoring of suspicious operations is performed by an automatic system, that terminates the
detected suspicious operations and informs officers, responsible for anti- by the money
laundering and (or) terrorists financing. Moreover, indirect monitoring is performed by
employees of the Company (according to their position description), who informs the Director of
the Company immediately in case of suspicion or detection of a risky transaction.
52. The Company guarantees that assessing by the money laundering and (or) terrorists
financing risk, it uses the most recent precise information. A person supervises and updates data
on customers and beneficiaries identities: a customer must update or approve his/her/its
personal identification data each 6 months (with a possibility to postpone it). In case of a 3-fold
delay, the Companys services become forbidden till the data is updated (if the update is
postponed, the data is asked to update within a week from the date it was postponed). In case
there is a suspicion that data is not precise or is old, it is asked to be updated in less than 6
months. This provision is valid for the new and actual customers.
53. The employees of the Company must not perform monetary operations, start business
relations, and perform transactions in case they are not able to implement the requirements, laid
down in art. 14, 16, 17-43, 45, IV.3, 48 of the Instructions, related to an appropriate check of the
customers and the beneficiaries.
54. In case the circumstances, laid down in art. 49 of this Instructions, arise, the Financial Crime
Investigation Service at the Ministry of Interior of the Republic of Lithuania (herein FCIS)
shall be informed immediately.
55. When monitoring the employee of the Company shall:
55.1 pay extra attention to the following:
55.1.1 activity that he/she considers to be related to by the money laundering and (or) terrorists
financing due to its origin, especially to all complex and extraordinary large monetary operations
and transactions, their structures without an obvious economical or legal aim, and business
relations or monetary operations with customers, including the entities from the third states,
which do not apply/applies insufficiently/do not meet the international standards for anti- by the
money laundering and (or) terrorists financing measures. The results of investigation on
transaction ground and aim shall be reasoned with documents and saved for 10 years;
55.1.2 monetary operations and transactions with the aim to hide identity of a customer or a
beneficiary, business relations or transactions with an unidentified customer or one, who does
not participate directly;

55.1.3 the fact whether a customer is included to the Consolidated list of persons, groups and
entities subject to EU financial sanctions ( the updated list is introduced on an official EC
website at http://europa.eu.int/comm/external_relations/cfsp/sanctions/list/consol-list.htm).
55.1.4 monetary operations, performed by the following persons:
55.1.4.1 persons without the citizenship and foreigners, focusing on their submitted identification
documents;
55.1.4.2 companies, managed by formal shareholders and (or) with declared shares, etc.;
55.2 upon the necessity to take immediate measures in order to prevent the money laundering
and (or) terrorists financing activities.
56. The Law on MLTFP allows the Company:
56.1 to identify a customer or a beneficiary without their direct participation;
56.2 to use the third party information on a customer or a beneficiary in a process of
identification.
57. In case a customer avoids or denies submitting information on the origin of funds or assets,
other additional documents upon the Companys request and in the requested terms, the latter has
a right to terminate transactions or business relations and to inform the FCIS.
V. Identifying, terminating and informing the FCIS on the suspicious monetary operations
58. The Company informs The FCIS on the customers suspicious monetary operations and
transactions.
59. The Company informs the FCIS in case it knows, suspects or has a sufficient basis to suspect
the money laundering and (or) terrorists financing activities in past, present or future time.
60. Monetary operations and transactions, mentioned in art. 58 of this Order are detected
according to the following:
60.1 criteria, laid down in the Decision of the Government, defined in art. 13;
60.2 conditional features of criteria, set by the Company and agreed with the FCIS, defining the
monetary operation or transaction to be suspicious;
60.3 the Company is performing a permanent monitoring of customers business relations,
including investigation of the transactions that have been concluded during the relations, as laid
down in art. IV.3 of this Order.
61. The FCIS is informed on the customers monetary operations, laid down in art. 58 of this
Order, regardless of their size. The main criteria are suspicion that the operation is risky. The
Company assesses whether the operation meets at least one feature, laid down in the criteria, laid
down in the Decision of the Government, defined in art. 13.
62. The Company has a right to inform the FCIS on monetary operations that do not meet any
criteria, if the employee of the Company doubts on the monetary operation. The suspicion could
be caused by objective and subjective circumstances, eg., a customer performs operations, not
typical for his/her/its activity, submits incorrect personal or monetary operation data, etc. The
employees of the Company have to receive as much information on monetary operation basis
and aims as possible, also have to prepare the written conclusions on the fact.
63. The Company has no obligation to investigate, whether the customers deed act contains
criminal features. In case of facts or suspicion on a suspicious monetary operation, the Company
must inform the FCIS.
64. The Company defines conditional features of a suspicious monetary operation, i.e. an
ordinary cooperation of a customer, also when a customer performs monetary operations or
concludes transactions without a clear economical basis, etc. The conditional features are agreed
with the FCIS and approved by them in order to assess the features adequately when informing.

65. Detecting that when a customer is performing monetary operations or concludes transactions
currently or has already performed them, the Company takes the following measures according
to the Decision of the Government of the Republic of Lithuania On approving the description
order of a list of criteria on the customers performed monetary operations or transactions to be
considered as extraordinary and suspicious and the termination of the extraordinary and
suspicious monetary operations or transactions and the information on the extraordinary and
suspicious monetary operations or transactions submission to the Financial Crime Investigation
Service at the Ministry of Interior, laid down in art. 13 of this Order:
65.1 terminates the monetary operation or the transaction;
65.2 immediately and within 3 business hours since the performing of the monetary operation or
the transaction or its termination, regardless of its sum, informs the FCIS on the identity of a
customer;
66. The Company pauses monetary operation or transactions for maximum 5 business days in the
following cases:
66.1 detection of a suspicious monetary operation or transaction;
66.2 reception of the FCIS written instructions to terminate customers suspicious monetary
operation or transaction. In this case the Company submits the requested information within 1
business day since request reception date.
67. The Company restarts the terminated monetary operation or transaction in case within 5
business days since the FCIS request or informing date there is no obligation to apply a terminal
ownership rights restriction, as laid down in the Criminal Procedure Code.
68. In case the Company receives the FCIS written instructions not to terminate customers
suspicious monetary operation or transaction, it does not terminate the latter since the reception
date if the termination could block the investigation on legalization of the criminally obtained
funds or assets, terrorists financing or other crimes, related to the money laundering and (or)
terrorists financing.
69. The information, laid down in the Law on the MLTFP, shall be transferred to the FCIS by email, computer storage devices or other agreed way. The Company agrees with the FCIS the way
of information submission. In case of a lack of data/impreciseness/incorrect form of submitted
information, the Company shall eliminate drawbacks and immediately at least within 7 business
days shall submit the information to the FCIS.
70. The Law on MLTFP defines an exemption, when the Company has no obligation to inform
the FCIS on the customers monetary operations.
VI. Final provisions
71. Sums in EUR, mentioned in the Instructions, are converted to LTL according to the official
EUR-LTL exchange rate of the Bank of Lithuania.
72. Violators of the Instructions are liable according to the actual legislation.
73. The Order comes into its legal force since 01/03/2015.

Annex 1 The form of the report for Financial Crime Investigation Service
The report for Financial Crime Investigation Service
1. Customer that is performing a suspicious monetary operation or transaction:
1.1 Physical person:
1.1.1 Name, surname____________________________________________________________
1.1.2 Personal identification number or other unique number that is designed to identify the
person_______________________________________________________________________
1.1.3 Bank account number______________________________________________________
1.1.4 Bank name_______________________________________________________________
1.2 Juridical person
1.2.1 Name and legal form________________________________________________________
1.2.2 Registration addresses_______________________________________________________
1.2.3 Company code_____________________________________________________________
1.2.4 Bank account number_______________________________________________________
1.2.5 Bank name________________________________________________________________
2.
Suspicion
criterion
for
monetary
operation
is
considered
suspicious
______________________________________________________________________________
3. Information about suspicious monetary operation or transaction:
3.1 Execution method___________________________________________________________
3.2 Execution date______________________________________________________________
3.3 Amount and currency________________________________________________________
3.4 Date and time of the suspension, if a suspicious monetary operation or transaction was
suspended_____________________________________________________________________
4. The person in whose favor monetary operation or transaction was formed:
4.1 Physical person:
4.1.1 Name, surname____________________________________________________________
4.1.2 Personal identification number or other unique number that is designed to identify the
person_______________________________________________________________________
4.1.3 Bank account number______________________________________________________
4.1.4 Bank name_______________________________________________________________
4.2 Juridical person
4.2.1 Name and legal form________________________________________________________
4.2.2 Registration addresses_______________________________________________________
4.2.3 Company code_____________________________________________________________
4.2.4 Bank account number_______________________________________________________
4.2.5 Bank name________________________________________________________________
Form filled: ______________________
(Signature)

_______________________________
(Name, surname)

Annex 2 Requirements for registration journal computers, communication, technology and office
equipment
Requirements for registration journal computers, communication, technology and office equipment
in UAB Mistertango
Registration journals are hosted on servers which contain all necessary systems for service delivery.
The company set the following requirements for registration journal computers, communication,
technology and office equipment:

All servers and their maintenance leased from third parties. It is ensured that the service providers
are choosen from EU member countries.

Common (minimum) System Requirements:

1 CPU 2.4 GHZ;
2 GB RAM;
20 GB disc space;
VDS/VPS (nonshared hosted);
50Mbps Internet;
Unix/linux OS su SSH;

PHP 5.2, MySQL 5.5, Apache su SSL.

Service provider is responsible for physical server security
Company system administrator is responsible for server network security and timely updating.
Database copies are made daily and stored in an external remote server. Remote server can not be
accessed by external system, it can be accessed only from certain IP addresses.
In order to secure client and server data exchanging, SSL certificates installed. The system can be
accessed through valid https protocol.
Network equipment and computers are maintained in accordance with manufacturer's
recommendations in a technical state of constant monitoring, maintenance and troubleshooting
carried out by qualified professionals.

Annex 3 Employees that are responsible for UAB Mistertango implementation of inner conduct
order to implement money laundering and terrorist financing preventive measures

Employees implementing inner conduct order to implement money laundering and terrorist
financing preventive measures
The company appoint a senior staff member who organizes the money laundering and terrorist financing
preventive measures in the company and suspend suspicious monetary operations or transactions:
General director: Audrius Ramanauskas
Address: Perknkiemio str. 2, LT-12126 Vilnius
tel.: +37069949555
e-mail: audrius@mistertango.lt
The company also designate a person responsible for communication with the Financial Crime
Investigation Service, administration of registration journals and information representation to the
Financial Crime Investigation Service:
General director: Audrius Ramanauskas
Address: Perknkiemio atr. 2, LT-12126 Vilnius
tel.: +37069949555
e-mail: audrius@mistertango.lt

EMPLOYEES
Position, name, surname
Employment agreement
I have read and agree to comply with this order:
(Name, surname, signature, date)

Position, name, surname

Employment agreement
I have read and agree to comply with this order:
(Name, surname, signature, date)

Position, name, surname

Employment agreement
I have read and agree to comply with this order:
(Name, surname, signature, date)