Policy of the AML

POLICY ON THE PREVENTION OF MONEY LAUNDERING/TERRORIST FINANCING AND KNOW YOUR CUSTOMER POLICY

 TopUp-Balance.com - SIAMOCEAN OÜ (hereinafter referred to as the Company) incorporated under the laws of the Republic of Estonia is the global Internet platform for purchasing gift cards and mobile balance. POLICY ON THE PREVENTION OF MONEY LAUNDERING /TERRORIST FINANCING AND KNOW YOUR CUSTOMER POLICY (hereinafter referred to as the Policy) is designed to prevent and reduce possible risks of TopUp-Balance.com to be involved in any illegal activity.

 TopUp-Balance.com, in accordance with the international and local legislative acts, implements effective internal procedures and mechanisms for prevention of money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and response to any kind of suspicious activity by its Users.

 Money Laundering (legitimization of proceeds of a crime) means “transfer of property knowing that this property is derived from criminal activity or from participating in such activity, in order to conceal its unlawful origin or provide assistance to any person involved in such activity to avoid legal consequences of his/her actions.”

 Terrorist Financing means “deliberate money provision or collection by any means, directly or indirectly, with intent to use this money or provided that it will be used for terroristic attacks.”

 All companies must comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (hereinafter referred to as the Regulations) and be informed about the guidelines established by the Joint Money Laundering Steering Group (hereinafter referred to as the Group), which prescribe in the Great Britain the guiding principles for the companies about the procedure of comprehensive overview of their customers, and recommendations of the Financial Action Task Force (FATF) that is an inter-governmental body which, first of all, is focused on the development and promotion of the national and global policy on combating the money laundering and terrorist financing.

 The other legislative acts concerning combating legitimization of proceeds of a crime and terrorist financing include:

5th Anti-Money Laundering Directive (EU) 2018/843;

Anti-Terrorism Acts of 2000 and 2001;

Counter-Terrorism Act 2008 where there is a detailed list of crimes related to participation in events for assistance, collection, or use of funds for terrorist purposes;

Financial Conduct Authority's Handbook.

 Applying the approach based on risk evaluation within the Know Your Customer Policy and the Policy on the Prevention of Money Laundering, SIAMOCEAN OÜ has taken measures as follows:

- Development and application of the Know Your Customer Policy, comprehensive overview of customers, as well as the extended overview of customers on the basis of the risk evaluation;

- Development of users’ verification sector based on the risk evaluation;

Processing of requests of the law enforcement authorities and local governmental authorities;

Reporting on suspicious activities;

Using various anti-fraudster systems;

Conducting relevant trainings for every company’s employee.

 Risk Evaluation

 TopUp-Balance.com, in accordance with the international requirements, applies the risk evaluation practice to combat money laundering and terrorist financing. By applying the risk evaluation practice to combat money laundering, the company ensures comparability of money laundering and terrorist financing preventing or impeding measures with the risks revealed.

 User Verification

 TopUp-Balance.com has implemented own procedures of verification in compliance with the strict requirements of the standards of the procedures for combating money laundering and preventing terrorist financing.

< TopUp-Balance.com’s verification procedure consists of three user’s data collection levels:

person’s identity verification – at this stage TopUp-Balance.com requires from a user to submit personal information in text form and a digital copy of his/her international passport;

selfie verification – at this stage TopUp-Balance.com requires from the user to submit his/her photo with the document in his/her hand near his/her face;

payment card verification, if the user chooses card payment as payment means. At this stage the user shall fill out the form with information about the bank card which he/she would like to use on TopUp-Balance.com. Thereafter, he/she shall send a photo with the card in his/her hand near his/her face where he/she hides 8 card number digits in the middle.

 This AML policy has been worked out in English and may be translated into other languages for your convenience. You can access and view other language versions by changing the language settings on Topup-balance.com website. In the event the translated version (into the language other than English) of this AML policy comes into conflict to any extent with its English version, the provisions of the English version shall prevail.