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Effective Date: October 25, 2024

Purpose and scope

This policy aims to define KPpay's commitment to the prevention and detection of illegal activities such as money laundering, terrorist financing and the proliferation of weapons of mass destruction. It applies to all KPpay operations, subsidiaries, employees and partners, in accordance with the international standards for combating financial crime laid down by the FATF, GIABA and other relevant authorities.

Guiding Principles

KPpay implements this policy in accordance with the following principles:

Prevention: Assess and mitigate AML/CFT/FP risks in all company operations.
Detection: Actively monitor and identify suspicious transactions.
Declaration: Inform the relevant authorities of any suspicious activity in compliance with local and international legal requirements.
Collaboration: Facilitate the exchange of information with regulators and authorities in charge of fighting financial crime.

Customer Identification and Verification (KYC)

KPpay applies a rigorous KYC procedure for all its customers:

Initial identification: Verify the identity of customers before establishing business relationships.
Beneficial owners: Identify and verify the beneficial owners of each customer, particularly for legal entities and complex structures.
Politically Exposed Persons (PEPs): Apply reinforced measures for PEPs, including their family members and close associates.
Update: Regularly reassess customer information to ensure accuracy and compliance with standards.

Risk Assessment and Management (Risk-Based Approach)

Risk Assessment : KPpay's approach to AML/CFT/FP is risk-based

Customer classification : Categorize customers according to risk levels (low, medium, high) and adapt control measures accordingly.

Resource allocation : Deploy resources on a priority basis to areas and entities with heightened AML/CFT/FP risks.

Transaction Monitoring and Suspicious Transaction Reporting

KPpay continuously monitors transactions to identify suspicious activity:

Automated alerts : Use analysis tools to detect unusual or suspicious transactions.
Statement of Suspicion : Report any suspicious operations to the appropriate authorities, in accordance with local regulations.
Attempted Suspicious Transactions : Extend reporting obligations to unsuccessful attempted transactions deemed suspicious.

Targeted Financial Sanctions and Asset Freezes

In accordance with international standards, KPpay undertakes to apply the targeted financial sanctions imposed by the competent authorities:

Asset freeze : Take measures to freeze the assets of designated individuals or entities involved in AML/CFT/FP activities.
Transaction Monitoring : Carry out checks on transactions involving persons, entities or countries subject to international sanctions.
Compliance : Ensuring compliance with decisions to freeze and seize criminal assets.

Preventing the Financing of the Proliferation of Weapons of Mass Destruction

KPpay implements strict measures to prevent any involvement in proliferation financing :

Control of Sensitive Transactions : check transactions involving products or services that could be used for the proliferation of weapons of mass destruction.
Application des sanctions : Appliquer rigoureusement les sanctions relatives au financement de la prolifération des armes conformément aux recommandations du GAFI.

Training and Awareness

KPpay invests in training and awareness-raising for its staff to ensure effective application of the AML/CFT/FP policy:

Initial and ongoing training : Provide regular AML/CFT/FP training for all employees, including transaction management and red flag recognition.
Partner awareness : Educate business partners and service providers about KPpay's AML/CFT/FP commitments.
Compliance Culture : Promote a culture of compliance to ensure that all employees understand their role in preventing financial crime risks.

Roles and responsibilities

Responsibilities for implementing this policy are clearly defined:

Management responsibility : KPpay's Compliance Committee is responsible for developing, implementing and updating this policy.
Employee responsibility : Each employee must comply with AML/CFT/PT procedures and report any suspicious activity.
Compliance function : A dedicated compliance officer oversees internal AML/CFT/FP controls.

National and international cooperation

KPpay recognizes the importance of cooperation in the fight against financial crime:

Judicial cooperation : working with judicial authorities and international bodies to share information and facilitate investigations.
Information exchange : Participate in information exchanges as part of international networks to combat money laundering and the financing of terrorism.
Inter-institutional cooperation : Work with other financial and non-financial institutions to ensure a coordinated and coherent approach.

Internal Controls and Audit

Internal controls and regular audits are carried out to assess the effectiveness of this policy:

Periodic Controls : Review operations to verify compliance with AML/CFT/FP procedures.
Independent Audits : Engage external auditors to assess and validate the effectiveness of KPpay's AML/CFT/FP controls.
Continuous improvement : Adapt processes in line with audit recommendations and regulatory changes.

Conclusion

KPpay is firmly committed to contributing to the global fight against money laundering, the financing of terrorism and the proliferation of weapons of mass destruction. By applying this policy and collaborating with regulators, KPpay ensures that it plays an active part in protecting the integrity and stability of global financial systems.