Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Introduction

esimway.com, operated by SIAMOCEAN OÜ, a company incorporated under the laws of the Republic of Estonia (registration code: 14774840), is a global online platform for purchasing gift cards and mobile top-up services.

This AML and KYC Policy (hereinafter referred to as the “Policy”) is established to prevent and minimize the risk of esimway.com being involved in any kind of illegal activity, including money laundering, terrorist financing, fraud, and other crimes.

The Company implements effective internal procedures and mechanisms in accordance with international and local regulations to:

• Prevent money laundering and terrorist financing;
• Combat drug and human trafficking;
• Prevent the proliferation of weapons of mass destruction;
• Eliminate corruption and bribery;
• Identify and respond to any suspicious activity by its users.

Definitions

• Money Laundering: The process of concealing the origins of money obtained from criminal activity, often by means of transfers involving foreign banks or legitimate businesses.
• Terrorist Financing: The act of collecting or providing funds, directly or indirectly, with the intention that they be used for terrorism-related purposes.

Regulatory Framework

The Company adheres to the requirements of the following regulations and guidelines:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (UK);
• The 5th Anti-Money Laundering Directive (EU) 2018/843;
• The Anti-Terrorism Acts of 2000 and 2001 (UK);
• The Counter-Terrorism Act 2008 (UK);
• The Financial Conduct Authority’s Handbook (UK);
• Recommendations of the Financial Action Task Force (FATF);
• Guidelines of the Joint Money Laundering Steering Group (JMLSG).

Measures Implemented

Applying a risk-based approach under this Policy, SIAMOCEAN OÜ has established the following internal practices:

• Development and enforcement of a comprehensive Know Your Customer (KYC) policy;
• Enhanced due diligence based on risk level and transaction behavior;
• Implementation of a multi-level user verification system;
• Cooperation with law enforcement and regulatory authorities;
• Timely reporting of suspicious transactions;
• Deployment of anti-fraud and transaction monitoring systems;
• Ongoing AML/KYC training for all company employees.

Risk-Based Approach

In compliance with international standards, esimway.com applies a risk-based approach to AML and KYC procedures. This means identifying and evaluating the risks associated with each user and transaction, and applying proportionate measures to mitigate them.

User Verification

To comply with applicable laws and maintain platform integrity, esimway.com has established a three-level user verification process:

1. Identity Verification
   • Submission of full name, date of birth, and a digital copy of a valid government-issued ID (e.g. passport).
2. Selfie Verification
   • A clear selfie of the user holding the same ID next to their face to ensure the document belongs to the user.
3. Payment Card Verification(when using card payment)
   • A form with the cardholder’s details must be completed.
   • A photo of the user holding their bank card next to their face is required, with 8 middle digits of the card number hidden for security.

All documents are processed in accordance with our Privacy Policy and applicable data protection laws.

Language and Interpretation

This AML Policy is written in English and may be translated into other languages for convenience. In case of any conflict between translated versions and the English version, the English version shall prevail.