1. Policy Statement
Ninpay Global Limited (hereinafter referred to as the "Company") strictly complies with the Anti-Money
Laundering and Counter-Terrorist Financing Ordinance (AMLO) of the Hong Kong Special Administrative
Region and other applicable anti-money laundering laws and regulations. The Company is committed to
implementing effective anti-money laundering and counter-terrorist financing (AML/CFT) measures to
prevent the use of the Company's services for illegal activities.
2. Risk assessment and customer due diligence
2.1 Customer Identification Procedures
Before entering into a business relationship with a customer, the Company will carry out the following
customer due diligence measures:
- Identify and verify customer identity
- Identification of the beneficial beneficiary
- Understand the nature and purpose of the client's business
- Continuously monitor business relationships
2.2 Strengthen due diligence
For high-risk customers (such as politically exposed persons, customers from high-risk countries, etc.),
the Company will implement enhanced due diligence measures, including but not limited to:
- Obtain senior management approvals
- Obtain additional identification documents
- Review trading activity more frequently
- Know where the funding is coming from
3. Transaction Monitoring and Reporting
3.1 Identification of suspicious transactions
The Company has established a transaction monitoring system to identify suspicious activities that may
be related to money laundering or terrorist financing, including but not limited to:
- Unusually large transactions
- Complex trading patterns
- Transactions that have no apparent economic or legitimate purpose
- Transactions involving high-risk countries
3.2 Reporting Obligations
Upon detection of suspicious transactions or activities, the Company will immediately file a Suspicious
Transaction Report (STR) with the Joint Financial Intelligence Unit (JFIU) in Hong Kong and cease the
relevant transactions to the extent permitted by law.
4. Record Keeping
The Company will retain customer identification information and transaction records for at least 7 years
after the termination of the business relationship, including:
- A copy of the customer's identification document
- Account Documents
- Business correspondence
- Transaction records and related documents
5. Employee training
The company will provide regular anti-money laundering training to all relevant employees, including:
- Anti-money laundering laws and regulations
- Customer Due Diligence Procedures
- Suspicious transaction identification and reporting
- Internal Policies and Procedures
New employees will receive basic anti-money laundering training within one month of employment, and all
employees will receive renewal training at least once a year.
6. Compliance Oversight
The Company has appointed a Compliance Officer who is responsible for overseeing the implementation of
the Anti-Money Laundering Policy, including:
- Ensure that policies are up to date with the latest regulatory requirements
- Oversee the suspicious transaction reporting process
- Organize staff training
- Reports to senior management on a regular basis
