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KYC & AML Policy

KYC & AML Policy

Parties

This Know Your Customer (“KYC”) and Anti–Money Laundering & Counter–Terrorist Financing (“AML”) Policy (“Policy”) is made between PASIFIC Technology FZCO (“Company,” “we,” “us,” or “our”), a company incorporated under the laws of the United Arab Emirates with its principal place of business in Dubai, and any natural or legal person who purchases Digital Goods through the Company’s online platform (“Customer”).


1. Definitions

  • AML Policy: Anti–Money Laundering and Counter–Terrorist Financing Policy.
  • PCMLTFA: Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
  • KYC (Know Your Customer): Procedures carried out to verify the identity of the Customer.
  • Ongoing Monitoring: Periodic review of business relationships according to their risk rating.


2. Proceeds of Crime and Terrorist Financing Act (PCMLTFA)

Under the PCMLTFA, the Company must fulfill record-keeping, customer identification, and reporting obligations. To that end, we:

  • Establish internal policies, procedures, and controls to prevent misuse of our products or services for illicit purposes.
  • Apply KYC procedures to all Customers.
  • Regularly assess our money-laundering and terrorist-financing risks.
  • Comply with the document-retention requirements prescribed by the PCMLTFA.
  • Monitor transactions for suspicious activity and file Suspicious Transaction Reports (STRs) or Attempted Suspicious Transaction Reports (ASTRs) as needed.
  • Provide ongoing compliance training to our employees.
  • Review the effectiveness of our compliance regime every two years.


3. Ongoing Monitoring of Business Relationships

A business relationship is established once a Customer conducts two or more commercial transactions (excluding closed-loop gift card purchases) within a 12-month period. In that context, we:

  • Verify the Customer’s identity.
  • Assign and update a risk rating (high/low) to each relationship.
  • Monitor the relationship periodically according to its risk rating.
  • Record the measures taken and information obtained during monitoring.
  • Request additional documentation or information to verify the source of funds if necessary.


4. Know Your Customer (KYC) Processes

Before a Customer may transact, we verify identity using one or more of the following:

  • Email address
  • Mobile phone number
  • Full legal name
  • IP address and device information
  • Copy of identity card or passport
  • Any additional information or documents requested by our compliance team


5. Reporting Suspicious Activity

If we detect unexplained or unusual patterns during our monitoring, we gather further information. The Compliance Officer logs and reviews all internally reported concerns to determine whether an STR should be filed with FINTRAC. If we cannot satisfactorily verify a Customer’s identity or source of funds, the account may be closed, the business relationship terminated, and the Customer blacklisted to prevent re-registration.


6. Contact

For questions or concerns regarding this Policy or its implementation, please contact legal@p2s.gg.


PASIFIC Technology FZCO reserves the right to update this Policy at any time. Changes take effect upon publication on our website.

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