KYC & AML Policy at SeaPay®

Updated – April 07, 2023

ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY FOR SEAPAY –
MARINE BANKING SERVICES

1. PURPOSE

THE PURPOSE OF THIS AML & KYC POLICY IS TO OUTLINE THE PROCEDURES AND MEASURES THAT SEAPAY LTD – MARINE BANKING SERVICES (HEREAFTER REFERRED TO AS “SEAPAY”) HAS IMPLEMENTED TO PREVENT AND DETECT MONEY LAUNDERING, TERRORIST FINANCING, AND OTHER ILLICIT ACTIVITIES, AND TO ENSURE THAT WE COMPLY WITH ALL RELEVANT AML AND KYC REGULATIONS.

2. SCOPE

THIS POLICY APPLIES TO ALL EMPLOYEES, AGENTS, AND CONTRACTORS OF SEAPAY, AS WELL AS TO ALL CUSTOMERS AND COUNTERPARTIES OF SEAPAY.

3. CUSTOMER IDENTIFICATION PROGRAM (CIP)

SEAPAY HAS IMPLEMENTED A CIP THAT INCLUDES THE FOLLOWING PROCEDURES:
– VERIFYING THE IDENTITY OF ALL CUSTOMERS AND COUNTERPARTIES, INCLUDING INDIVIDUALS AND LEGAL ENTITIES, USING RELIABLE, INDEPENDENT SOURCE DOCUMENTS, DATA, OR INFORMATION.
– OBTAINING INFORMATION ABOUT THE PURPOSE AND INTENDED NATURE OF THE BUSINESS RELATIONSHIP.
– CONDUCTING ONGOING MONITORING OF THE CUSTOMER RELATIONSHIP AND UPDATING CUSTOMER INFORMATION ON A REGULAR BASIS.

4. ENHANCED DUE DILIGENCE (EDD)

SEAPAY HAS IMPLEMENTED EDD PROCEDURES FOR HIGHER-RISK CUSTOMERS AND COUNTERPARTIES, INCLUDING THOSE THAT MAY POSE A HIGHER RISK OF MONEY LAUNDERING OR TERRORIST FINANCING. EDD MEASURES MAY INCLUDE:
– OBTAINING ADDITIONAL INFORMATION ABOUT THE CUSTOMER OR COUNTERPARTY, SUCH AS THE SOURCE OF FUNDS AND BENEFICIAL OWNERSHIP.
– CONDUCTING MORE FREQUENT AND THOROUGH MONITORING OF THE CUSTOMER RELATIONSHIP.
– OBTAINING SENIOR MANAGEMENT APPROVAL BEFORE ESTABLISHING OR CONTINUING A BUSINESS RELATIONSHIP WITH A HIGHER-RISK CUSTOMER OR COUNTERPARTY.

5. SUSPICIOUS ACTIVITY REPORTING (SAR)

SEAPAY HAS IMPLEMENTED SAR PROCEDURES FOR THE REPORTING OF SUSPICIOUS ACTIVITIES OR TRANSACTIONS THAT MAY BE INDICATIVE OF MONEY LAUNDERING OR TERRORIST FINANCING. ALL EMPLOYEES ARE REQUIRED TO REPORT ANY SUSPICIOUS ACTIVITIES OR TRANSACTIONS TO THE DESIGNATED AML COMPLIANCE OFFICER, WHO WILL THEN DETERMINE IF A SAR SHOULD BE FILED WITH THE RELEVANT AUTHORITIES.

6. RECORD KEEPING

SEAPAY MAINTAINS RECORDS OF ALL CUSTOMER IDENTIFICATION INFORMATION AND TRANSACTIONAL RECORDS FOR A PERIOD OF AT LEAST FIVE YEARS.

7. TRAINING

ALL EMPLOYEES, AGENTS, AND CONTRACTORS OF SEAPAY RECEIVE REGULAR TRAINING ON AML AND KYC REGULATIONS, AS WELL AS ON THE COMPANY’S AML & KYC POLICIES AND PROCEDURES.

8. INDEPENDENT REVIEW

SEAPAY CONDUCTS AN INDEPENDENT REVIEW OF ITS AML & KYC POLICIES AND PROCEDURES ON A REGULAR BASIS TO ENSURE THAT THEY REMAIN EFFECTIVE AND COMPLIANT WITH ALL RELEVANT REGULATIONS.

9. COMPLIANCE WITH LOCAL REGULATIONS

SEAPAY COMPLIES WITH ALL LOCAL AML AND KYC REGULATIONS, AS WELL AS WITH ANY APPLICABLE INTERNATIONAL REGULATIONS.

10. DESIGNATED AML COMPLIANCE OFFICER

SEAPAY HAS DESIGNATED AN AML COMPLIANCE OFFICER WHO IS RESPONSIBLE FOR OVERSEEING THE COMPANY’S AML & KYC POLICIES AND PROCEDURES, AS WELL AS FOR ENSURING THAT THE COMPANY REMAINS COMPLIANT WITH ALL RELEVANT REGULATIONS.

71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Tel +447480045023 Web https://seapay.me