AML Policy

At ConciergePay, we are committed to preventing money laundering, terrorist financing, and financial crime. Our AML Policy ensures compliance with international and local regulatory requirements, while providing secure, discreet, and high-quality service to our clients.

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1. Purpose

The purpose of this policy is to:

• Prevent the use of ConciergePay for money laundering or terrorist financing.

• Ensure full compliance with applicable laws, regulations, and industry best practices.

• Protect our clients, our platform, and our reputation.

2. Scope

This policy applies to:

• All employees, contractors, and representatives of ConciergePay.

• All clients using ConciergePay services, including high-net-worth individuals, family offices, and institutions.

• All transactions, including cross-border fund transfers and related advisory services.

3. Client Due Diligence (CDD)

ConciergePay performs rigorous due diligence on all clients, including:

• Verification of identity using government-issued documents (passport, ID, proof of address).

• Assessment of source of funds and wealth to ensure legitimacy.

• Screening against sanctions lists, politically exposed persons (PEPs), and adverse media.

• Risk-based categorization of clients to determine ongoing monitoring levels.

4. Enhanced Due Diligence (EDD)

For high-risk clients or transactions, ConciergePay applies enhanced due diligence, including:

• Detailed verification of beneficial ownership.

• Scrutiny of transaction purpose, jurisdiction, and volume.

• Additional documentation or assurances to verify legitimacy.

5. Transaction Monitoring

All transactions are monitored for unusual or suspicious activity, including:

• Large or irregular fund transfers inconsistent with the client’s profile.

• Transactions involving high-risk jurisdictions or entities.

• Structuring or splitting transactions to avoid reporting thresholds.

Suspicious transactions are escalated immediately to our Compliance Officer.

6. Reporting Obligations

ConciergePay is committed to regulatory reporting:

• Suspicious activity is reported to relevant authorities in accordance with local laws.

• All regulatory obligations, including record-keeping and reporting thresholds, are strictly adhered to.

7. Record-Keeping

ConciergePay maintains secure records of:

• Client identification and verification documents

• Transaction details

• Compliance checks and risk assessments

Records are retained in accordance with regulatory requirements and internal policies.

8. Employee Training

All ConciergePay personnel undergo mandatory AML training, including:

• Identification of suspicious activity

• Procedures for client onboarding and enhanced due diligence

• Awareness of applicable AML laws and regulations

9. Roles and Responsibilities

• Compliance Officer: Oversees implementation of the AML Policy, reporting, and ongoing monitoring.

• Employees: Required to comply with the policy, report suspicious activity, and maintain confidentiality.

• Management: Ensures adequate resources, training, and enforcement of AML standards.

10. Review and Updates

This policy is reviewed periodically to ensure alignment with current laws, regulations, and best practices. Updates are communicated to all personnel and applied immediately to ConciergePay operations.

11. Contact and Reporting

For questions or to report suspicious activity:

Compliance Officer: Robert Tigi
Email: roberttigi@conciergepay.com
Phone: 07393908896