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Aml Policies

Introduction and Legal Basis

Jilimine maintains an AML/CTF program designed to prevent money laundering, terrorist financing, and related financial crimes in all activities conducted on the platform. This policy governs customer onboarding, ongoing monitoring, reporting, and cooperation with competent authorities, and is implemented in accordance with applicable laws and FATF guidance. The policy applies to all customers, employees, contractors, and service providers acting on behalf of Jilimine.

Definitions

  • Customer Due Diligence (CDD): the process of verifying a customer’s identity and assessing risk before or during business relationships and transactions.
  • Enhanced Due Diligence (EDD): heightened scrutiny applied to higher-risk customers, including additional verification of funds and wealth, and senior-oversight approval.
  • Politically Exposed Person (PEP): an individual who holds or has held a prominent public function and is considered higher risk for ML/TF concerns.
  • Unusual Transaction Report (UTR): a formal report of suspicious or unusual activity in accordance with applicable reporting requirements.
  • Sanctions Screening: ongoing screening against global sanctions and restricted party lists.
  • KYC: Know Your Customer obligations to verify customer identity and assess risk.

Customer Identification and Verification (CDD) and Enhanced Due Diligence (EDD)

Onboarding and ongoing business with the platform require verification of the customer’s identity. Verification is mandatory prior to processing financial transactions above the applicable threshold, and at onboarding for new customers regardless of initial transaction value. The following information must be collected and verified: full name, date of birth, nationality, residential address, and government-issued identification. Verification may be conducted through a combination of documentary checks and, where appropriate, electronic verification tools.

Enhanced Due Diligence applies to higher-risk customers, including, but not limited to, encounters involving high-risk jurisdictions, complex ownership structures, or unusual funding patterns. EDD requires: assessment of source of funds and source of wealth, correlation with declared business activities, and approval by senior compliance personnel.

As part of CDD/EDD, Jilimine maintains ongoing monitoring of identity information and transactions to identify changes that could affect risk status.

Sanctions, PEP Screening and Ongoing Monitoring

All customers are screened at onboarding and on an ongoing basis against global sanctions lists and PEP databases. Screening results are reviewed by the Compliance Department, and any positive hits or elevated risk triggers are escalated for additional documentation or action. Ongoing monitoring analyzes transaction patterns, destination counterparties, and changes in customer information to identify indicators of money laundering or terrorist financing.

Record Keeping

Jilimine retains relevant KYC documentation, transaction records, and communications for a minimum period of five (5) years from the date of last activity or the end of the business relationship, whichever is later. Records are stored securely, protected by access controls, and available to authorities under lawful process.

Reporting of Unusual Transactions and No-Tipping-Off

Suspicious or unusual activity must be reported promptly to the competent financial intelligence unit in accordance with applicable law. Jilimine maintains strict confidentiality around dealings with regulators and internal investigations, and undertakes no disclosure to the customer or third parties that would reveal that a report has been filed, except as required by law or regulatory process.

Risk-Based Approach

Jilimine employs a risk-based framework to allocate resources commensurate with risk. Risk factors include customer geography, transaction size and frequency, product and service types, source of funds, and customer behavior. Higher-risk profiles trigger enhanced due diligence, increased monitoring, and more frequent management review.

Client Obligations

By creating an account or using the platform, customers agree to: provide accurate and complete KYC information; promptly update any information that affects risk; disclose the source of funds and, when necessary, the source of wealth; and comply with requests for additional documentation or verification. Failure to comply may result in account restrictions, temporary suspension, or termination of the relationship.

Account Termination and Freezing

Jilimine reserves the right to terminate or freeze an account where verification cannot be completed, information provided is false or misleading, the customer is subject to sanctions, or risk indicators indicate potential ML/TF activity. Frozen funds may be withheld or blocked in accordance with applicable law and regulatory obligations, and authorities may be notified where appropriate.

Training, Third-Party Verification and Compliance Oversight

Staff receive ongoing AML/CTF training covering red-flag indicators, escalation procedures, and reporting obligations. Jilimine may rely on authorized FATF-compliant third-party service providers for identity verification and documentation checks, subject to written contracts, audit trails, and ongoing oversight.

Data Protection and Privacy

All KYC and transactional data are processed in accordance with applicable data protection laws. Access to personal data is restricted to authorized personnel, protected by appropriate technical and organizational measures, and retained as long as necessary for AML/CTF compliance and regulatory obligations.

Policy Availability and Updates

A condensed version of this policy is available to customers for awareness purposes. The full AML/CTF policy may be provided to regulators, partners, or institutional stakeholders upon legitimate request. Any material changes will be communicated in accordance with regulatory obligations.

Contacts

For compliance inquiries, please contact the Jilimine Compliance Department at [email protected] or through the official support channels designated by Jilimine. The Compliance Department oversees the implementation, audits, and updates of AML/CTF measures in accordance with applicable law and regulatory expectations.

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