AML Policy
77ph is committed to preventing money laundering, terrorist financing, and other illicit activities on its platform. This AML Policy outlines the systems, controls, and procedures 77ph employs to identify, assess, and mitigate AML/CFT risk in relation to customer onboarding, ongoing activity, and transactions.
Scope and Purpose
This policy applies to all customers and activity conducted on the 77ph platform and governs the handling of customer information, due diligence, and reporting obligations in all jurisdictions where 77ph operates, as permitted by law.
Legal and Regulatory Basis
77ph operates in accordance with applicable anti money laundering and countering financing of terrorism laws and regulations. The policy adopts a risk based approach to customer due diligence and ongoing monitoring and requires cooperation with law enforcement and regulatory authorities as permitted by law.
Customer Due Diligence and KYC
77ph applies a risk based approach to customer due diligence. The level of verification increases with higher risk indicators and higher transaction values. The core components are identity verification, due diligence on source of funds, and ongoing monitoring of activity.
Identity Verification
Customers must provide government issued identification documents that are valid and clearly display the user name, date of birth, and photograph. Acceptable documents include a valid passport, national identity card, or driver’s license. The document must be current and legible.
Address Verification
To confirm residential address, customers must provide one of the following documents dated within the last three months: utility bill (electricity, water, gas, internet, or telephone), bank statement, or official government correspondence. The document must show the customer name and residential address.
Payment Method Verification
For security and compliance reasons, 77ph may require verification of the payment method used to fund the account. Acceptable verifications include: a copy of the front side of the payment card with only the first six and last four digits visible and the CVV redacted, or a screenshot or statement confirming ownership of the payment instrument capable of confirming the account holder’s name and ownership.
Age Verification
77ph prohibits participation by individuals under the minimum legal age in their jurisdiction. The minimum age is 18 unless a higher age applies locally. If there is any suspicion of underage activity, the account will be suspended pending verification of age.
Enhanced Due Diligence
For high risk customers or high risk transactions, 77ph will require additional documentation and checks. This may include evidence of the source of funds, expected transaction patterns, documentation of business ownership where applicable, and enhanced monitoring of transactions and account activity.
Ongoing Monitoring and Transaction Monitoring
77ph applies ongoing risk based monitoring of customer activity and transactions. The monitoring includes anomaly detection, pattern analysis, and reviews of sudden changes in activity. Any suspicious activity or discrepancies will be escalated to the AML compliance team and may be reported to the relevant authorities as required by law.
Data Protection and Privacy
77ph processes personal data collected for AML and KYC purposes in accordance with applicable data protection laws. Personal data is stored securely, access is restricted to authorized personnel, and processing is limited to purposes related to compliance and account administration. Data may be shared with regulators or law enforcement as permitted by law and as necessary for compliance.
Data Retention and Records
Personal data collected for AML and KYC purposes will be retained for eight years from the date of last activity or account closure, or longer as required by applicable law or regulator guidance. Records of verification documents will be kept in a secure manner consistent with retention obligations.
Non-Compliance and Account Restrictions
Failure to complete verification, or to comply with AML requirements, may result in: (a) temporary or permanent restrictions on account activity including deposits and withdrawals; (b) suspension or closure of the account; (c) reporting of suspicious activity to competent authorities as required by law. 77ph reserves the right to take proportionate actions based on risk assessment.
Cooperation with Regulators and Reporting
77ph will cooperate with regulators and law enforcement authorities in the detection and prevention of money laundering and terrorist financing, including provision of information as required by law and regulatory obligations.
Policy Review and Updates
This AML Policy is reviewed at least annually and whenever material changes occur in law, regulation, or the risk profile of 77ph. Updated policy will be communicated to customers through standard channels and will take effect on publication unless otherwise stated.
Contact Information
For questions or requests related to AML and KYC, please contact the 77ph AML team at [email protected] or the general support team at [email protected].
