Anti-Money Laundering Policy

In terms of law, money laundering means legalizing the proceeds of crime, i.e. actions that conceal the source of funds in order to make their nature lawful.

Anti-money laundering (AML) incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business community. That is why national and international laws make it illegal for STICPAY and its employees to be knowingly or recklessly engaged in any activity related to such illegally gained capital.

Implemented Procedures

STICPAY implements a strong anti-laundering policy to ensure that its customers will be identified for such suspicions up to a certain standard to minimize the procedural complications for genuine and legitimate customers. In order to fulfil its commitment to provide full assistance to governments combating such illegal financial transactions, STICPAY has developed a technologically advanced and reliable electronic system, which completely verifies its client identity and is able to maintain detailed record of all previous financial transactions.

STICPAY makes sure to track all suspicious activities and report any of these to the relevant law enforcement bodies. That is why complete legal protection is provided to clients who share confidential financial data with the company.

To discourage money laundering and related illegal activities, STICPAY does not deal in cash transactions whether to deposit or withdraw funds. Our company reserves the right to suspend any transaction where it finds even a suspicion of money laundering.

STICPAY collects identification data of every Client, as well as IP addresses, online activity, communications and, in general, all transactions carried out by the Client.

STICPAY tracks, including auto-monitoring and auto-controlling, suspicious activities of the clients and transactions executed under unusual conditions. These include, but are not limited to, transactions that do not make economic sense, unexplained large transactions, transactions involving unidentified parties, investments related transactions of unclear nature. STICPAY reserves the right to ask supporting documentation for the suspicious transactions.

UUsers must notify STICPAY in case they identify any unauthorized transactions in their account. Enhanced Due Diligence is exercised on high-risk customers, high turnover customers and/or potential suspicious customers/transactions. The purpose of the transaction is established where applicable.

STICPAY improves its AML procedures continuously to monitor unlawful financial schemes.

STICPAY reserves the right to refuse to process a transaction at any stage, when we believe that the transaction is associated with money laundering or other criminal activity.

STICPAY complies with the legal requirements of Malaysia for anti-money laundering. In cases set forth in the relevant legal enactments, we co-operate with officials and government institutions of Malaysia, as well as other countries.

STICPAY does not offer its services to residents of certain jurisdictions such as Cuba, Sudan, Syria and North Korea and listed / relevant parties of Consolidated United Nations Security Council Sanctions Lists.

Non-acceptable use Policy

STICPAY has also an established non-acceptable use policy which clearly states the business models that will not be acceptable. Those include, but are not limited to:

• Material which incites or promote violence and/or racism
• Prescription drugs, illegal drugs
• Illegal tobacco products
• Firearms and weapons
• Pornography, child pornography, adult material
• Satellite and cable TV descramblers
• Any fake or counterfeit government ID’s, Visas, Licenses or other
• Any goods or services that infringe on the intellectual property rights of third parties
• Pyramid or Ponzi scheme products or third-party payment processing or payment aggregation products, multi-level marketing and other “get-rich-quick” schemes or high yield investment programs
• Prepaid or other stored value cards that are not associated with a merchant and/or are not limited to purchases of particular products or services
• Unlicensed gambling services of any type

Non-acceptable customers/individuals

The Company will not establish a Business Relationship with customers / groups of customers that present unacceptably high risks. Customers whose acceptance must be refused, if they are natural persons or legal entities, must meet one or more of the following criteria:

• Reside in countries considered sanctioned countries
• The intended purpose of use of the account is defined as “Non-Acceptable”
• Are included in National or Supra-National Sanctions lists as “Sanctioned person or entity”
• There is available public information about involvement or investigation for drug manufacturing, drug trafficking, people smuggling, sexual servitude, illegal logging / phishing, fraud or organized theft, corruption
• Fail or refuse to provide the Company with requested information or documents
• Provide false or misleading information

Compliance Regime

Like other financial institutions, STICPAY has also set up a compliance regime in order to fulfil its formal legal requirements. This includes the appointment of a Compliance Officer, policy making, regular review of their implementation and impact and professional compliance training to staff members. STICPAY also ensures regular updating of its electronic systems to modern rules and regulations developed for more sophisticated checks to trace money laundering and other criminal financial practices. Professional training is provided to STICPAY’s employees to trace such illegal activities and to use modern technological systems, which constitutes part of STICPAY’s essential policies.

Additional Disclosure

Identification

In order to fully comply with anti-money laundering laws, STICPAY demands, at a minimum, two kinds of documents for the satisfactory identification and verification of customers' account. The first one is a government issued document with a photo of the customer on it. It can be a passport, driving license or regular ID card which must be issued by the government. The second one is any utility bill, bank statement or government-issued document with the complete name and address information on it. The proof of address must be issued within the last three months from the application date. Moreover, STICPAY requires an electronic signed application form submission. On a case by case basis, STICPAY may require additional documentation from its clients in order to comply with the due diligence process, which may vary for customers from country to country.

Customers are also required to inform STICPAY if there are any changes to their personal information. In case documents are in a non-western language, they must first be translated into English by any official translator and this translated copy must be duly signed and certified by that translator and submitted along with other related documents and clients' photo on it.

Deposits and Withdrawals

In case of money deposits, the sender’s name must match the name of customer present in STICPAY record. No third-party mediation is allowed in this case so Mr. A cannot deposit money from his name for Mr. B. Similarly, in case of a money withdrawal, the recipient’s name must match the name of the account holder they are withdrawing money from. If the transaction is online money, then funds will only be withdrawn through same online transfer system to the same account from where it has been transferred.