1. Introduction

Pipze Market Limited ("we," "our," or "us") is committed to maintaining the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. This policy outlines our commitment to preventing money laundering and terrorist financing activities through our services.

We are committed to complying with all applicable AML/CTF laws and regulations in the jurisdictions where we operate, including but not limited to the Financial Action Task Force (FATF) recommendations and local regulatory requirements.

2. Policy Objectives

The objectives of this AML Policy are to:

• Prevent money laundering and terrorist financing activities
• Ensure compliance with applicable AML/CTF laws and regulations
• Protect our company and clients from financial crime risks
• Maintain the integrity of the financial system
• Establish clear procedures for identifying and reporting suspicious activities

3. Risk Assessment

We conduct regular risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our business activities. Our risk assessment considers:

• Client risk factors (geography, business type, transaction patterns)
• Product and service risk factors
• Geographic risk factors
• Delivery channel risk factors
• Technology and new payment methods risk factors

4. Customer Due Diligence (CDD)

4.1 Standard CDD

We apply standard CDD measures to all clients, including:

• Verification of client identity using reliable, independent sources
• Identification of beneficial owners
• Understanding the nature and purpose of the business relationship
• Ongoing monitoring of the business relationship

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to higher-risk clients, including:

• Politically exposed persons (PEPs)
• Clients from high-risk jurisdictions
• Clients with complex ownership structures
• Clients with unusual transaction patterns

5. Transaction Monitoring

We implement comprehensive transaction monitoring systems to detect suspicious activities, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with client profiles
• Complex or unusual transactions
• Transactions involving high-risk jurisdictions
• Transactions with no apparent economic or lawful purpose

6. Suspicious Activity Reporting

Our employees are trained to identify and report suspicious activities. When suspicious activity is detected:

• Immediate reporting to the Compliance Officer
• Documentation of all relevant details
• Assessment of whether a suspicious activity report (SAR) is required
• Filing of SARs with relevant authorities when necessary
• Maintenance of confidentiality of SAR filings

7. Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

• Client identification and verification documents
• Transaction records for at least 5 years
• CDD and EDD documentation
• Suspicious activity reports and supporting documentation
• Training records and compliance reports

8. Employee Training

All employees receive regular AML/CTF training, including:

• Recognition of suspicious activities
• CDD and EDD procedures
• Reporting requirements and procedures
• Regulatory updates and changes
• Consequences of non-compliance

9. Compliance Officer

We have designated a Compliance Officer responsible for:

• Overseeing AML/CTF compliance
• Reviewing and updating policies and procedures
• Conducting risk assessments
• Ensuring proper training and awareness
• Liaising with regulatory authorities

10. Sanctions Compliance

We maintain compliance with international sanctions programs:

• Regular screening against sanctions lists
• Blocking transactions involving sanctioned entities
• Reporting blocked transactions to relevant authorities
• Maintaining up-to-date sanctions screening systems

11. Third-Party Relationships

We conduct due diligence on third-party relationships:

• Assessment of third-party AML/CTF controls
• Regular review of third-party relationships
• Contractual requirements for AML/CTF compliance
• Monitoring of third-party performance

12. Regulatory Reporting

We maintain open communication with regulatory authorities:

• Timely submission of required reports
• Cooperation with regulatory inquiries
• Prompt notification of material compliance issues
• Regular regulatory updates and consultations

13. Policy Review and Updates

This AML Policy is reviewed and updated regularly to ensure:

• Compliance with current regulatory requirements
• Effectiveness of implemented measures
• Integration of lessons learned from incidents
• Alignment with industry best practices