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Policy of the AML

Policy on the Prevention of Money Laundering, Terrorist Financing, and Know Your Customer Policy

TopUp-Balance.com, operated by SIAMOCEAN OÜ (hereinafter referred to as the Company), is incorporated under the laws of the Republic of Estonia and serves as a global platform for purchasing gift cards, mobile balance, and eSIMs. This Policy on the Prevention of Money Laundering and Terrorist Financing and Know Your Customer (KYC) Policy (hereinafter referred to as the Policy) is designed to mitigate risks and prevent the involvement of TopUp-Balance.com in any illegal activities.

1. General Provisions

In compliance with international and local regulations, TopUp-Balance.com implements robust internal procedures and security mechanisms to prevent:

  • Money laundering
  • Terrorist financing
  • Drug and human trafficking
  • Proliferation of weapons of mass destruction
  • Corruption and bribery
  • Other illicit activities

The Company actively monitors and reports any suspicious transactions or user activities in accordance with legal requirements.

2. Definitions

Money Laundering: The process of disguising the origins of illegally obtained money by transferring it through a legitimate financial system to make it appear lawful.

Terrorist Financing: The provision, collection, or distribution of funds, either directly or indirectly, for use in terrorist activities.

Know Your Customer (KYC): A set of procedures used to verify the identity of users to prevent fraud, money laundering, and terrorist financing.

Suspicious Activity: Any transaction or behavior that raises red flags for potential involvement in illicit activities.

3. Regulatory Framework

TopUp-Balance.com adheres to the following legislative acts and international guidelines:

  • 5th Anti-Money Laundering Directive (EU) 2018/843
  • UK Anti-Terrorism Acts (2000, 2001, 2008)
  • Financial Conduct Authority’s Handbook (UK)
  • Recommendations of the Financial Action Task Force (FATF)
  • Guidelines established by the Joint Money Laundering Steering Group (JMLSG, UK)

4. AML and KYC Measures

To minimize financial crime risks, SIAMOCEAN OÜ has implemented the following measures:

  • Development and enforcement of KYC procedures, including user identity verification and risk-based customer assessment
  • Implementation of a user verification system based on risk evaluation
  • Monitoring of transactions and real-time fraud detection systems
  • Collaboration with regulatory and law enforcement authorities to process requests and assist in investigations
  • Mandatory reporting of suspicious activities to the relevant financial intelligence units
  • Regular AML compliance training for employees to stay updated with evolving regulations and risks

5. Risk Evaluation

In line with international AML standards, TopUp-Balance.com applies a Risk-Based Approach (RBA) to assess users and transactions. This ensures that higher-risk users and transactions undergo stricter scrutiny, while lower-risk users face minimal friction.

Factors influencing risk evaluation include:

  • Geographic location
  • Transaction patterns
  • Payment methods used
  • Identity verification status

6. User Verification Procedures

TopUp-Balance.com has established a three-tier verification process to ensure user authenticity and security:

  • Identity Verification: Users must provide personal information and submit a digital copy of their government-issued ID (passport or national ID card).
  • Selfie Verification: Users must upload a real-time photo (selfie) holding their ID next to their face to prevent identity fraud.
  • Payment Card Verification (if applicable): Users opting for card payments must provide a photo of themselves holding their card, ensuring the middle 8 digits are hidden for security reasons.

Failure to complete these verification steps may result in restricted account access or transaction limitations.

7. Compliance and Legal Obligations

TopUp-Balance.com reserves the right to:

  • Request additional documentation to verify a user's identity or source of funds.
  • Delay or refuse transactions that appear suspicious or violate AML regulations.
  • Suspend or terminate accounts involved in fraudulent or illegal activities.
  • Share user data with law enforcement agencies when legally required.

8. Policy Amendments

This AML Policy is subject to periodic review and updates to comply with changing regulations and emerging risks. If significant amendments are made, users will be notified through appropriate channels.

This policy is originally drafted in English and may be translated into other languages for convenience. In case of any discrepancies between translations, the English version shall prevail.