Anti-Money Laundering Agreement

1. Purpose of the Policy

1. 1

   Verify user identities and ensure registration information is authentic.

2. 2

   Confirm that deposited funds come from legitimate sources.

3. 3

   Detect and block suspicious fund flows.

4. 4

   Protect the Platform and its users from money laundering, fraud and illegal funds.

2. Scope of Application

1. 1

   All registered users of the Platform.

2. 2

   Platform partners.

3. 3

   Any natural or legal person using the Platform’s services.

3. Definition of Money Laundering

1. 1

   Transferring or converting property derived from criminal activity to conceal or disguise its illegal origin.

2. 2

   Concealing or disguising the true nature, source, movement or ownership of property.

3. 3

   Receiving, holding or using funds while knowing they come from criminal activity.

4. 4

   Participating in, assisting or instigating any of the above.

Money laundering is deemed to have occurred even if the underlying crime took place outside the country.

4. Organisation and Responsibilities

1. 1

   The Platform appoints an Anti-Money Laundering Compliance Officer (AMLCO) to oversee and enforce this policy.

2. 2

   The AMLCO reports directly to senior management.

3. 3

   All employees must cooperate with the AMLCO’s reviews, investigations and reporting.

5. Know Your Customer (KYC)

Before any transaction (deposit or withdrawal), users must complete identity verification:

1. 1

   Identity document (passport, national ID or driving licence — all four corners visible, clear and legible).

2. 2

   Proof of address (utility bill, bank statement or government letter dated within the last 3 months).

3. 3

   Same-name accounts: deposit and withdrawal accounts must belong to the same verified user.

4. 4

   High-risk users are reviewed periodically to keep information up to date.

6. Transaction Monitoring and Risk Detection

1. 6.1

   Three Lines of Defence

   1. 1

      Working with payment providers that have AML capabilities to intercept most suspicious deposits.

   2. 2

      An automated risk-control system that monitors abnormal transactions.

   3. 3

      Manual review and AMLCO investigation, with funds frozen where necessary.

2. 6.2

   Identifying Suspicious Activity (focusing on money moved in and out without real spending)

   1. 1

      Deposit equals withdrawal: e.g., deposit RM1,000 → immediately withdraw RM1,000.

   2. 2

      Funds returned to the source within a short time: e.g., withdrawal within 5 minutes of a deposit.

   3. 3

      No real spending: no mystery box purchases, only fund transfers.

   4. 4

      Multiple accounts linked to the same withdrawal account.

   5. 5

      Abnormal deposit channels: repeated deposits and withdrawals using different bank cards or virtual cards.

   6. 6

      Unusual activity: frequent deposits and withdrawals in a short period with no normal social or spending behaviour.

   7. 7

      Low spend ratio: only a small share of deposited funds (usually under 50%) is actually spent, with the rest quickly withdrawn to the original source.

Freezing of abnormal transactions: once suspicious activity is detected, the Platform reserves the right to freeze funds and request proof of their origin.

7. Handling of Suspicious Transactions

1. 1

   Automatic detection: the system flags transactions with suspected money-laundering features as “high-risk”.

2. 2

   Manual review: the AMLCO reviews the transaction records and the user’s history.

3. 3

   Additional documents: users may be asked for proof of fund origin or an explanation of the transaction.

4. 4

   Outcome:

   1. a

      Legitimate funds → withdrawal resumed.

   2. b

      Unclear origin or refusal to cooperate → account frozen and reported to the regulators.

8. Data Retention

1. 1

   Identity verification and transaction records are kept for at least 7 years.

2. 2

   Records are subject to inspection and audit by regulators.

9. Training and Audit

1. 1

   Employees receive regular AML training.

2. 2

   The AMLCO reviews the implementation of AML measures every quarter.