1. Purpose and Principles

Jilipg maintains an anti-money laundering and countering the financing of terrorism (AML/CFT) program to prevent the use of its services for illegal activity. The program applies a risk‑based approach, aligns with applicable laws and regulatory expectations, and integrates Know Your Customer (KYC), ongoing transaction monitoring, and timely reporting to competent authorities where required.

2. Scope and Application

This policy governs all customer onboarding, account management, and all payment flows processed by Jilipg, including deposits, withdrawals, internal transfers, and bonus-related transactions. It covers all platforms, products, and geographies in which Jilipg operates, subject to applicable law and licensing constraints.

3. Definitions

  • Money Laundering: The procurement or transfer of funds or assets derived from criminal activity, or used to conceal their illicit origin, including facilitation of such activity.
  • Source of Funds (SOF): The origin of funds that a customer uses to conduct a transaction or make a deposit.
  • Source of Wealth (SOW): The overall origin and accumulation of a customer's wealth, including business ownership, employment, inheritance, or investments.
  • KYC (Know Your Customer) / CDD (Customer Due Diligence): Processes to verify customer identity and assess risk prior to and during the business relationship.
  • EDD (Enhanced Due Diligence): heightened verification and monitoring for higher‑risk customers or transactions.
  • Sanctions and Geo-blocking: Screening against applicable sanctions lists and restricting access from or to listed jurisdictions as required by law.
  • PEP (Politically Exposed Person): Individuals who may pose higher risk due to public office or affiliations.
  • CTF: Countering the financing of terrorism.

4. Governance and Roles

The AML program is overseen by an AML Compliance Officer (ACLO) who reports to senior management. The ACLO coordinates risk assessment, policy implementation, training, and the escalation process. A dedicated compliance team conducts ongoing monitoring, investigations, and reporting support. The board maintains ultimate responsibility for AML controls and effectiveness.

5. Enterprise-Wide Risk Assessment (EWRA)

Jilipg conducts an annual EWRA to identify material AML/CFT risks across customers, products, geographies, and channels. Risk scores inform threshold settings for due diligence, monitoring intensity, and escalation procedures. The EWRA is reviewed for updates when regulatory or business changes occur.

6. Know Your Customer (KYC) and Customer Due Diligence

Jilipg applies a three‑step verification framework to establish and maintain accurate customer information and to assess risk before and during the business relationship.

  1. Step 1 — Identity Verification: Every customer must provide verifiable identity information before enabling withdrawals. Required data include full legal name, date of birth, country of residence, current address, and government‑issued identity documentation. Documents must be clear, legible, and current. The customer must provide equivalent information across payment methods used for funding.
  2. Step 2 — Source of Funds (SOF): For deposits above USD 2,000 or withdrawals above USD 2,000 or transfers to another user above USD 1,000, the customer must substantiate the SOF with one or more of: bank statement, payroll/payment slip, tax return, or other documentation confirming the source of funds. Documentation must clearly show the customer name and the date.
  3. Step 3 — Source of Wealth (SOW) and Enhanced Due Diligence: For deposits, withdrawals, or transfers exceeding USD 5,000, or any high‑risk scenario identified by EWRA, the customer provides SOW documentation (ownership of business, major investments, inheritance, etc.) and undergoes enhanced due diligence, which may include corroborating information from third‑party sources. A risk assessment determines the required level of verification and ongoing monitoring.

Ongoing KYC means updating customer information when changes occur and re‑verifying identity and risk as warranted by activity or regulatory requirements.

7. Sanctions Compliance and Geo-blocking

Jilipg screens customers and payment counterparties against applicable sanctions, embargoes, and high‑risk jurisdictions. Access from or to restricted jurisdictions is blocked, and activities from sanctioned individuals or entities are prohibited. The list of restricted jurisdictions is reviewed and updated in line with regulatory obligations.

8. Transaction Monitoring and Due Diligence

Ongoing monitoring operates on two levels:

  • First Line of Control: Payment services partners integrated with Jilipg implement robust AML controls. Transactions are screened against customer profiles and known risk indicators before processing.
  • Second Line of Control: Jilipg AML staff review transactions and related events to identify unusual patterns, including rapid successive deposits/withdrawals, mismatched funding methods, or activity inconsistent with the customer profile. Automated systems support detection with human oversight.

Triggers for enhanced review include high‑risk geography, unusual transaction sizes, rapid activity changes, or new funding sources. Transactions that appear atypical are escalated for further investigation.

9. Suspicious Transaction Reporting (STR)

Staff must document and report any suspicious activity or anomalies in accordance with internal procedures and regulatory requirements. The AML team evaluates each report and determines whether a formal STR must be filed with the competent financial intelligence unit (FIU) and whether to terminate the business relationship. All STRs are kept confidential in line with applicable laws.

10. Record Keeping and Data Retention

Jilipg retains KYC, transaction, and due diligence records for a minimum of ten years from the end of the customer relationship or longer where required by law. Records include identity documents, verification results, funding sources, risk assessments, and monitoring outcomes. Data handling complies with applicable privacy and data security requirements.

11. Training and Awareness

All personnel with AML responsibilities receive initial and ongoing training on KYC, transaction monitoring, STR filing, and data protection. Training is updated to reflect regulatory changes, emerging risk indicators, and internal control enhancements.

12. Independent Audit and Testing

The AML program undergoes periodic independent audits and testing to validate design and effectiveness. Audit findings are documented; remediation timelines are established and tracked until closure.

13. Vendor Management

Jilipg performs due diligence on third‑party service providers involved in payments or data handling, requiring adherence to AML/CFT standards, data security, and reporting obligations. Contracts include access controls, data handling, and incident notification requirements.

14. Data Privacy and Security

Customer data used for AML purposes is protected by appropriate technical and organizational measures. Access is restricted to authorized personnel, and data is encrypted in transit and at rest. Retention, processing, and disclosure comply with applicable privacy laws and regulatory orders.

15. Business Continuity and Incident Response

Jilipg maintains a business continuity plan ensuring continued effectiveness of AML controls during disruptions. Security incidents affecting AML data are managed through an incident response process, with timely notification to authorities where required by law and internal procedures.

16. Policy Updates and Version Control

This policy is reviewed at least annually or as regulatory changes necessitate. Updates are approved by senior management, with changes communicated to relevant staff and documented in the policy history.