AML/KYC policy

The Compliance Officer is the person, duly authorized by us, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of our anti-money laundering and counter-terrorist financing, including but not limited to:

• Collecting customers’ identification information;
• Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
• Monitoring transactions and investigating any significant deviations from normal activity;
• Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
• Updating risk assessment regularly;
• Providing law enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which is involved in the prevention of money laundering, terrorist financing and other illegal activities.

We, in line with the international requirements, have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed by priorities so that the greatest risks receive the highest attention.

Our identity verification procedure requires the customer provide us with the following documents during the registration according to AML/KYC policies:

1. Identity Document – this is a valid, reliable and independent source document with the following information:

• full name;
• date of birth;
• customer’s photo, and
• identity document serial number.

The customer is free to provide one of the following types of documents:

• National ID card (both sides) or national passport;
• International passport;
• Driving license (both sides).

Please note that we accept documents as proof of your identity only if all the information in it is provided with Latin transliteration.

2. Proof of address – this is a document confirming the customer’s residence containing full name, address and was issued not more than 3 months ago. The customer is free to provide one of the following types of documents:

• Certified tenancy agreement or a bank statement;
• Utility or electricity bill;
• Tax return or council tax;
• Other official documents with current resident address, full name and issued not more than 3 months ago.

Please note that we accept documents as proof of address only if all the information in it is provided with Latin transliteration.

3. “Selfie” – photo of yourself holding one of the ID documents (mentioned in “a” above) and a sheet of paper with the inscription “ccpay.com.sg” and the current date.

We will take steps to confirm the authenticity of documents and information provided by the customer. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain customers who have been determined to be risky or suspicious.

We reserve the right to verify a customer’s identity on an ongoing basis, especially when his identification information has been changed or his activity seemed to be suspicious (unusual for the particular customer). In addition, we reserve the right to request up-to-date documents from the customer, even though he has passed identity verification in the past.

Customer’s identification information will be collected, stored, shared and protected strictly by our Privacy Policy and related regulations.

We reserve the right to reject any person who registered with us through ccpay.com.sg and disallow them from using our services if we are unable to verify any information due to non-cooperation of the customer, or if the customer’s actions are likely to have a material adverse effect on us for violating any applicable laws or industry best-practice guidelines.

We may from time to time temporarily reject customers from some countries/territories. The current list of such countries/territories can be reviewed here. This applies to both new customers at the registration stage and existing users of our services. In the latter case, we will notify the client of the refusal to provide services in advance and provide a reasonable time for the termination of the use of our services.

The customers are known not only by verifying their identity (who they are) but, more important, by analyzing their transactional patterns (what they do). Therefore, we rely on data analysis as a risk assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, recordkeeping, investigation management, and reporting. System functionalities include:

1. A daily check of customers against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing customers on watch and service denial lists, opening cases for investigation if it is essential, sending internal communications and filling out statutory reports, if applicable;
2. Case and document management.

CCPay demonstrates a strong commitment to maintaining the integrity of its website services.

1. The company constantly analyzes all provided customer data and monitors with all transactions and it has the right to:

• • monitor and control all transactions using automated screening, particularly employment of the Crystal Blockchain Analytics Tool or any other transaction monitoring tool and manual screening aimed at prompt identification of high-risk transactions. Transaction monitoring systems are reviewed regularly to ensure the system is operating appropriately and effectively.
  • analyze customers’ historical information and other contextual profile data (placing requests, offers, input and output data, website activity tracking, etc.).
  • monitor and control unnecessarily complex and unusual transactions to identify different suspicious actions.

1. In case of detection of any suspicious or toxic transactions, ccpay.com.sg follows the algorithm:

• • request the customer to provide any additional information or documents in case of suspicious transactions.
  • temporary suspend (lockout) or deactivate a user account if data provided by the user is fictitious (false, incomplete or misleading) about the origin of funds.
  • terminate the user account and cancel all transactions engaged in suspicious (fraudulent) activities.

1. Upon detection of any suspicious (fraudulent) transactions, the company reserves the right to employ corresponding prevention measures without prior notice or explanation to the user, which include but are not limited to:

• • blocking/closing of the existing/open client’s transactions on the website.
  • restricting and/or blocking access to the website.
  • cancellation of all deposit/withdrawal transactions deemed as suspicious (fraudulent).
  • reporting of any suspicious user’s transactions to the relevant enforcing authorities.

About the AML/KYC Policy, we will analyse all provided customers data and monitor all transactions and it reserves the right to:

• ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
• request the customer to provide any additional information and documents in case of suspicious transactions;
• temporary suspend (block) or terminate the customer’s account when we have reasonable suspicion that such customer is engaged in illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor customers’ transactions on a day-to-day basis to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.