Compliance Management System Overview

Our Commitment to Compliance

Kriptomat operates with a strong focus on integrity, transparency, and sustainability. Our Compliance Management System (CMS) ensures that we meet all relevant regulatory obligations, follow international standards (e.g., ISO 37301, MiCAR, AML/CTF rules), and uphold the highest ethical standards in everything we do.

Compliance is not just a requirement—it is a core part of our corporate culture, decision-making, and day-to-day operations.

Purpose of the CMS

This is a public extract of Kriptomat’s internal CMS Policy, published to ensure transparency.

The CMS provides a framework to ensure  that:

• Kriptomat remains compliant with applicable laws and regulations.
• We prevent misconduct, manage risks, and continuously improve our processes.
• All employees and external partners follow clearly defined ethical and legal expectations.

Key Features of Our Compliance Framework

• ISO 37301 certified Compliance Management System
• Integrated Code of Conduct, AML/CTF framework, and Risk-Based Approach
• Alignment with MiCAR Articles 62(2)(q) and 81 for crypto-asset portfolio management
• Independent Compliance Function reporting directly to the Management Board
• Ongoing compliance risk assessments and internal controls
• Access to a secure whistleblowing platform and internal reporting channels
• Continuous compliance training and awareness-building for employees and partners

Governance and Oversight

• Top-down leadership: The Management Board is actively involved and accountable.
• Three Lines of Defence model: Operations, Compliance, and Internal Audit.
• Regular updates to the Supervisory Board. 
• Regular internal audits, performance evaluations, and external certification.
• Clear allocation of roles and responsibilities across all departments.

Stakeholder Trust

Our CMS helps us build and maintain trust with:

• Clients (retail and institutional)
• Regulators (e.g., EFSRA, FIU, SEPBLAC, HANFA)
• Business partners, banks, and financial institutions
• Investors and law enforcement authorities

Reporting Misconduct or Concerns

We encourage all clients, employees, and partners to report any suspected misconduct or compliance concerns.

• Email: [email protected] 
• Anonymous Reporting: Speak up (Whistleblower) Platform

Why It Matters

Compliance is not just about avoiding fines—it’s about doing business the right way. Our CMS ensures that we protect our users, support market integrity, and help build a sustainable and trusted crypto ecosystem.