AML Policy

ZeGidPay is committed to complying with all applicable anti-money laundering (AML) regulations. This policy outlines our procedures for identifying, preventing, and reporting suspicious activity.

1. Definitions

• Anti-money laundering (AML) is the process of detecting and preventing the use of the financial system for money laundering or terrorist financing.
• Money laundering is the process of concealing the origin of illegally obtained money.
• Terrorist financing is the process of providing financial support to terrorist organizations.
• Suspicious activity is any transaction or pattern of transactions that indicates money laundering or terrorist financing.

2. Responsibilities

• The Chief Compliance Officer (CCO) is responsible for developing and implementing ZeGidPay's AML program.
• All employees are responsible for understanding and complying with the AML policy.

3. Customer due diligence (CDD)

ZeGidPay will conduct CDD on all customers. CDD includes collecting and verifying the customer's identity, understanding the customer's business, and assessing the customer's risk of money laundering or terrorist financing.

4. Monitoring transactions

ZeGidPay will monitor all transactions for suspicious activity. This includes identifying unusual or suspicious patterns of transactions.

5. Reporting suspicious activity

ZeGidPay will report any suspicious activity to the appropriate authorities. This includes the Financial Crimes Enforcement Network (FinCEN) in the United States.

6. Training

ZeGidPay will provide training to all employees on AML compliance. This training will cover the AML policy, the risks of money laundering and terrorist financing, and the procedures for reporting suspicious activity.

7. Compliance review

ZeGidPay will conduct regular reviews of its AML program to ensure that it is effective. These reviews will be conducted by the CCO or another independent party.

8. Sanctions compliance

ZeGidPay will comply with all applicable sanctions regulations. This includes sanctions imposed by the United Nations, the European Union, and the United States.

9. Recordkeeping

ZeGidPay will maintain records of all transactions and CDD information for a period of five years.

10. Enforcement

ZeGidPay will enforce its AML policy consistently. Any employee who violates the policy will be subject to disciplinary action, up to and including termination of employment.

This policy is intended to be a living document that will be updated as needed. ZeGidPay is committed to AML compliance and will take all necessary steps to prevent money laundering and terrorist financing.