Kyc & Aml Policies

Introduction

9999ph maintains this AML and KYC policy to prevent money laundering and the financing of crime and to comply with applicable laws and regulatory expectations. This policy governs all customer interactions, account openings, deposits, withdrawals, and any related activities conducted on our platform.

Scope and Objectives

The objectives are to prevent illicit activity, verify customer identity, understand customers' risk profiles, monitor transactions on a risk-based basis, and report any suspicious activity to the competent authorities in accordance with law. This policy applies to all customers, prospective customers, and any person acting on behalf of a customer.

Risk-Based Approach

We apply a risk-based framework consistent with FATF guidance and local regulation. Risks are evaluated by customer type, geography, source of funds, and expected transaction patterns. Controls are proportionate to the identified risk and reviewed at least annually.

Customer Identification and Verification

On onboarding, 9999ph will collect and verify the following information and documents to establish the customer's identity and residence:

• Full legal name, date of birth, nationality, and residential address;
• Government-issued identification document (passport, national ID, or driving license) valid at the time of verification;
• Proof of address not older than three months (utility bill, bank statement, or government correspondence);
• For higher-risk customers or larger transactions: source of funds and source of wealth information; bank statements and/or pay slips as evidence;
• Consent to verify information using independent databases and, if necessary, a live verification check (video or selfie with the document).

Enhanced Due Diligence (EDD) and High-Risk Customers

Customers presenting elevated risk triggers enhanced due diligence measures. Triggers include high-value activity, international transfers, recognition as a Politically Exposed Person, or residence in a high-risk jurisdiction. EDD requires additional documentation, ongoing monitoring, and, where appropriate, senior management approval.

Source of Funds and Source of Wealth

We require reasonable evidence of the source of funds for deposits, withdrawals, or transfers that are inconsistent with the customer’s known profile or exceed internal thresholds. Documentation may include bank statements, payslips, tax assessments, or other legitimate evidence. The company may request statements directly from financial institutions where permissible.

Politically Exposed Persons and High-Risk Jurisdictions

Customers identified as Politically Exposed Persons or connected to high-risk jurisdictions will be subject to enhanced verification and ongoing monitoring. Verification includes additional documentation and, where necessary, independent verification. FATF-listed or regulator-identified high-risk jurisdictions may result in restrictions on account activities to mitigate risk.

Ongoing Monitoring and Transaction Monitoring

All customer activity is monitored on an ongoing basis to identify unusual patterns. The monitoring program assesses deposit and withdrawal activity, transaction sizes, geolocation, device data, and consistency with declared profile and business activity. Deviations prompt enhanced review or escalation.

Suspicious Activity Reporting and Escalation

Employees must report grounds for knowledge or suspicion of money laundering or terrorist financing to the nominated officer promptly. Tipping off or disclosure of an AML concern to the customer or other parties is strictly prohibited. SARs are submitted to the appropriate authority in accordance with law, and all investigations remain confidential. Escalation pathways ensure timely action and risk mitigation.

Record Keeping and Data Retention

We maintain detailed records of customer identification, verification results, transaction data, risk assessments, SARs, and communications with regulators in a secure, access-controlled environment. Records are retained for not less than five years after account closure or the end of the business relationship, or longer if required by applicable law.

Roles and Responsibilities

Senior management holds ultimate responsibility for AML/CTF compliance. A Money Laundering Reporting Officer (MLRO) is designated to receive disclosures, direct investigations, and coordinate regulatory reporting. Staff training is provided on a regular basis, covering CDD/EDD, SAR procedures, and escalation.

Third-Party Relationships and Vendor Vetting

New suppliers and service providers undergo due diligence equivalent to customer due diligence. Ongoing monitoring is applied to relationships with suppliers to ensure compliance with AML standards and to assess risk contributions to the business.

Data Privacy, Security, and Legal Compliance

All processing of personal data complies with applicable data protection laws. We implement access controls, encryption, secure storage, and defined retention schedules. Data transfers and sharing are restricted to legitimate regulatory or business purposes with appropriate safeguards.

Amendments and Review

This policy is reviewed at least annually and whenever there are significant regulatory or business changes. Material amendments require approval by the board. Customers will be notified of material changes in accordance with our communications policy.