Anti-Money Laundering and Know Your Customer Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy has been implemented by Smart Energy to ensure that the company does not become involved in illegal financial activities and complies with all applicable laws and regulations. The policy is regularly updated to reflect legal developments and international best practices in the area of AML/KYC. SEP acts in accordance with all relevant anti-money laundering and anti-terrorist financing regulations.

1. Introduction

This Anti-Money Laundering and Know Your Customer (AML/KYC) Policy is established by Smart Energy Pay Solutions Ltd to prevent the Company's involvement in illicit financial activities and to ensure compliance with applicable laws and regulations. This policy may be amended from time to time to reflect legislative developments and best global practices in AML and KYC compliance. SEP complies with laws and standards aimed at combatting money laundering and the financing of terrorism.

2. Definitions

3. Initial and Ongoing Screening

Smart Energy Pay Solutions Ltd performs thorough due diligence on all users during onboarding and continuously throughout the business relationship. This includes screening against global sanctions lists and monitoring transactional behavior to identify irregularities. Suspicious or high-risk activity may result in service denial, delayed transactions, or reporting to regulators.

4. KYC/AML Identification Procedures

Smart Energy Pay Solutions Ltd applies a risk-based approach in line with legal obligations. We identify and verify users' identities using reliable independent documentation. This includes gathering information about the nature of the relationship, source of funds, and beneficial ownership where applicable. For individuals: Identification is verified using official documents such as a passport, ID card, or driver's license. For legal entities: Documentation includes incorporation certificates, organizational structure, and director and shareholder information. If identification is performed remotely, enhanced verification measures are applied, including video calls and notarized translations where necessary.

5. Ongoing Monitoring of Users

Smart Energy Pay Solutions Ltd regularly reviews and updates user information and monitors transactions to ensure consistency with users' risk profiles. We perform enhanced scrutiny for high-value or unusual activity, and reassess user risk based on updated data and transaction behavior. Transactions equal to USD 1000 will undergo Enhanced Due Diligence (EDD), including checks on the source of funds and wealth. Real-time monitoring tools and compliance oversight by the Money Laundering Reporting Officer (MLRO) support effective risk management.

6. Sanctioned, Prohibited, and High-Risk Jurisdictions

Smart Energy Pay Solutions Ltd maintains lists of sanctioned, prohibited, and high-risk jurisdictions. These lists are based on assessments by FATF and other regulatory bodies. Users associated with sanctioned or prohibited jurisdictions are not permitted to use Smart Energy's services. Users from high-risk jurisdictions are subject to enhanced due diligence.

7. High-Risk Situations

For users deemed high-risk—such as those from high-risk jurisdictions or who are politically exposed—Smart Energy will apply enhanced due diligence. This includes senior management approval, verification of the source of funds and wealth, and ongoing scrutiny of the business relationship.

8. Record-Keeping

Smart Energy Pay Solutions Ltd retains transaction and user identification records for a minimum of five (5) years, in compliance with PCMLTFA and AML regulatory obligations. This ensures adequate evidence for any future investigations or regulatory audits.

9. Money Laundering Reporting Officer (MLRO)

The MLRO is responsible for the effective implementation of Smart Energy Pay Solutions Ltd's AML/KYC program. The officer oversees due diligence, transaction monitoring, and ensures that suspicious activities are reported to the relevant authorities.

10. Reporting

Smart Energy Pay Solutions Ltd is obligated to report any suspected money laundering, terrorist financing, or illegal activity to regulatory authorities without notifying the user. Unauthorized disclosure of such reporting is a criminal offense under applicable law.