1. Principles: 

   1. Zayment Solutions Private Limited (‘Zayment’, ‘Us’, ‘Our’, ‘We’) is dedicated to upholding Anti-Money Laundering (‘AML’) and Counter-Terrorist Financing (‘CTF’) compliance. Our comprehensive compliance framework is designed to align with all Applicable Law. This Anti-Money Laundering Policy (referred to as ‘AML Policy’) establishes a structure to identify, detect, address, and mitigate risks related to financial crime.

   2. This AML Policy is applicable to all employees, officers, directors, third-party vendors, users, customers, and any other legal entities or individuals involved with Zayment’s functions and operations. Capitalised terms not explicitly defined within this policy will adopt the meanings established in our Terms of Service or Privacy Policy. If not defined therein, they will assume the meaning prescribed by Applicable Law.

   3. It is imperative to review this AML Policy thoroughly before accessing or utilising the Platform platform or any associated Services. By accessing or using any part of the Platform, You confirm Your Agreement to be bound by this AML Policy. Should You not agree to the Terms of Service, Privacy Policy, and/or this AML Policy, then You are prohibited from using any Services We provide on the Platform. You may only proceed with using the service at Your own risk if the Platform’s Terms of Use, Privacy Policy, and AML Policy are acceptable to You.

   4. We are committed to ensuring that:

      1. All operations adhere to applicable legal and regulatory requirements of the jurisdictions in which We operate.

      2. Periodic risk assessments are conducted to comprehend the risks of money laundering, terrorist financing, and proliferation financing associated with Our customers and the Platform.

      3. Appropriate AML procedures are operational and their effectiveness is continuously monitored.

      4. We endeavour to block the Platform from being used to facilitate or enable any money-laundering or terrorist financing activities.

      5. We will fully cooperate with law enforcement agencies as and when required.

2. User Responsibilities: By accessing, downloading, or using the Platform, Users acknowledge and agree to the following:

   1. They shall not use the Platform in any manner that contravenes its Terms of Service, Privacy Policy, AML Policy, or any Applicable Law.

   2. Users agree and consent to any changes made by Us without prior notice.

   3. All information submitted to Us during Platform use must be true, accurate, and complete. Any submitted information or identification document must genuinely belong to the User providing it.

   4. Should their address change, Users must notify Us and submit a new proof of address within six months of the change.

   5. Users shall not engage in any Suspicious Transaction or Money Laundering activity, nor interact with anyone on a Sanctions List. 

   6. ‘Sanctions List’ refers to lists of individuals and entities designated by any country, government, or international authority, including, but not limited to, the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’), the European Union, the Monetary Authority of Singapore, and relevant Applicable Laws. 

   7. A ‘Suspicious Transaction’ is defined as any transaction, including attempted ones, whether cash-based or not, which reasonably suggests involvement in:

      1. Proceeds of an offence specified under applicable anti-money laundering law, irrespective of value.

      2. Circumstances of unusual or unjustified complexity.

      3. A lack of economic rationale or genuine purpose.

      4. Financing of terrorist activities.

   8. At Our sole discretion, We may block, restrict, or terminate access to any User’s account if they are found to be engaged in, or suspected of engaging in, illegal activities.

3. Customer Due Diligence (CDD): To mitigate the risk of the Platform being misused by state and non-state actors for money laundering, terror, and proliferation financing, and to ensure strict adherence to applicable AML law, Our identity verification procedure mandates users to provide government-issued identity cards or other officially valid documents recognised by competent authorities. All collected information will be processed in accordance with our Privacy Policy. This is detailed in Our ‘KYC Policy’ available on the Platform.

4. Enhanced Due Diligence (EDD): EDD measures are applied to complex or unusually large transactions, unusual patterns of transactions, and users categorised as high risk. High-risk customers/users include politically exposed persons (PEPs) or those from high-risk jurisdictions. EDD measures involve obtaining additional information or verification, increased monitoring, and potentially restricting the types or volumes of transactions. These measures are deployed commensurate with the identified risk. This is detailed in Our ‘KYC Policy’ available on the Platform.

5. Transaction Monitoring: All customer transactions are monitored for unusual or suspicious activities, with the extent of monitoring varying based on each User’s risk profile. Our Compliance Officer will review and investigate suspicious transactions. In accordance with applicable law, any suspected, detected, or attempted suspicious transaction involving proceeds may be reported to the appropriate and competent authority.

6. During periodic checks, should We suspect or have reasons to suspect any transactions related to money-laundering, terrorist financing, or any other illegal activity, We may seek information to identify and verify the User's identity. By accessing, downloading, or using the Platform, each User acknowledges and agrees to assist and fully cooperate with Us in any query, investigation, or direction from a competent law enforcement authority.

7. Risk Assessment: 

   1. In compliance with Applicable Law, We have adopted a risk-based approach to combating money laundering and terrorist financing. To mitigate these risks, We categorise Our users into high-risk, medium-risk, and low-risk. Factors considered for risk assessment include, but are not limited to:

      1. Sufficiency and adequacy of submitted identification information.

      2. User’s geographical location.

      3. User(s) conducting extremely complex or high-value transactions.

      4. User(s) transacting with or within known high-risk jurisdictions.

      5. Countries subject to sanctions, embargoes, or similar measures.

      6. Countries identified by credible sources as having significant levels of corruption or other criminal activities.

      7. Countries or geographic areas identified by credible sources as providing funding or support for terrorist activities, or hosting designated terrorist organisations.

      8. Financial or social status.

      9. Nature of the User’s business activity and the regularity or duration of the business relationship.

      10. Guidance notes circulated by various governmental and intergovernmental organisations.

   2. All information pertaining to a User’s risk profile is maintained in strict confidentiality. The information collected for risk profiling is processed and stored according to Our Privacy Policy, with any disclosure occurring solely in accordance with that policy. Based on a User’s risk profile, We reserve the right, at Our sole discretion, to restrict, suspend, or terminate any User’s operation that contravenes Applicable Law.

8. Record Keeping: All information collected, processed, and stored by us will be handled in accordance with our Privacy Policy. Such collected data will be retained for such period as provided under Applicable Law. If no duration is prescribed by Applicable Law, then We shall retain such information for a period of five years.

9. Employee Training and Awareness: All relevant employees of Zayment receive regular training to understand this AML Policy and to recognise suspicious activities. Training programmes are updated to reflect changes in regulations or business operations.

10. Compliance and Enforcement: 

    1. We are dedicated to full compliance with applicable AML law, which includes cooperation with relevant regulatory bodies, courts, law enforcement, and other competent authorities. For any queries, please contact Our Money-Laundering Reporting Officer:

       1. Name: Ashita Batra

       2. Address: ZAYMENT SOLUTIONS PRIVATE LIMITED, Plot 66, #The Hub, LGF, Okhla Phase 3, Okhla Industrial Estate, New Delhi, South Delhi- 110020, Delhi

       3. E-mail: compliance@endl.app

    2. To enhance the integrity and transparency of transactions on the Platform, You are encouraged to report any information You possess or acquire regarding any Suspicious Transactions or transactions You find, or have reason to believe are dubious in nature, to Our Compliance Officer by emailing them at compliance@endl.app.

11. Policy Review: This AML Policy will be reviewed from time to time, in consideration of changes in regulations, industry practices, or the nature and complexity of the Platform’s Service(s). Any changes to this policy will be updated here. We urge all stakeholders to revisit this AML Policy and familiarise themselves with any amendments. For previous versions of this AML Policy, please contact us by emailing compliance@endl.app.

Note: Kindly note that this AML Policy serves as a guideline, and does not guarantee complete prevention against money-laundering or terrorist financing. We continuously strive to enhance our procedures and systems to prevent such activities.