Anti-money Laundering

Introduction

Smvip maintains a comprehensive Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program designed to detect, deter, and report activities that facilitate money laundering or the financing of terrorism. This Policy governs all Smvip accounts, transactions, and business relationships and reflects Smvip’s obligation to comply with applicable AML/CTF laws and international standards, including FATF guidance. The Policy applies to customers, employees, agents, and service providers in all jurisdictions where Smvip operates.

Regulatory Framework and Scope

Smvip’s AML/CTF program is implemented in accordance with the laws, regulations, and supervisory expectations applicable to the jurisdictions in which Smvip conducts business. The program covers customer due diligence, ongoing monitoring, suspicious activity reporting, recordkeeping, data privacy, and governance measures essential to preventing financial crime.

Customer Identification and Verification (CDD)

• Onboarding and account opening require identity verification prior to processing financial transactions above the threshold defined below. Smvip shall collect and verify information sufficient to establish the customer’s identity and assess risk.
• Required identity data includes: full legal name, date of birth, nationality, residential address, and government-issued identification (e.g., passport or national ID) with validity dates.
• Permanent and current address verification may be requested via documentation such as utility bills, bank statements, or official correspondence dated within the last three months.
• Customer information is verified using reliable, independent sources or corroborated documentation. Verification is conducted promptly, and ongoing accuracy is maintained throughout the business relationship.
• Threshold for verification: identity verification is mandatory before processing any financial transactions above the equivalent of 4,000 in the customer’s primary currency. Smvip may request additional information at any time based on risk indicators.

Enhanced Due Diligence (EDD)

Smvip applies Enhanced Due Diligence for higher‑risk customers and transactions. EDD measures include a detailed assessment of the source of funds and, where appropriate, the source of wealth, additional verification of identity, senior compliance review, and ongoing monitoring at heightened frequency. EDD determinations are documented and retained for audit purposes.

Sanctions, PEPs and Adverse Jurisdiction Screening

All customers undergo screening against applicable global sanctions lists and politically exposed persons (PEP) databases at onboarding and on an ongoing basis. If a match is identified, Smvip escalates for manual review and applies risk‑based controls, including account restrictions, enhanced monitoring, or refusal of service where legally permissible.

Ongoing Monitoring and Transaction Screening

Smvip maintains automated and manual monitoring of customer activity and payment flows. Key elements include:

• Risk scoring of customers based on known indicators, geography, and behavior patterns;
• Real-time screening of incoming and outgoing payments against internal risk rules and external indicators;
• Investigations triggered by unusual or incongruent activity, large or repetitive transactions, rapid movement of funds, or structures designed to obscure provenance;
• Periodic review of high‑risk accounts and updates to risk categorization as needed.

Reporting of Suspicious Activity

When Smvip identifies suspicious activity or transactions, it will be reported to the competent financial intelligence authority in accordance with applicable laws and regulations. Reports are submitted confidentially, and Smvip undertakes no disclosure to customers that would hinder an investigation, except as required by law. Internal investigations and decisions related to suspicious activity are controlled and documented in accordance with governance procedures.

Record Keeping and Data Retention

Smvip shall retain all records relevant to AML/CTF compliance for a minimum of five (5) years, or longer as required by applicable law. Retained records include customer identification documents, transaction records, risk assessments, and correspondence related to due diligence and monitoring. Records are stored securely and are accessible to competent authorities under lawful request.

Confidentiality and No-Tipping-Off

Smvip maintains strict confidentiality of all AML/CTF investigations. No customer shall be informed of an ongoing review or report, except as required by law. All internal communications and files related to AML/CTF matters are restricted to authorized personnel and retained in secure systems with audit trails.

Risk-Based Approach

Smvip operates a risk-based framework to calibrate control measures to the level of risk posed by each customer, product, and transaction. Risk factors include customer geography, expected source of funds, product type (high‑risk features), and transaction velocity/amount. Controls are periodically reviewed and adjusted to reflect evolving risk exposures.

Client Obligations

Customers consent to Smvip’s AML/CTF program as a condition of account creation. They must provide accurate and complete information, promptly update any changes, disclose the source of funds and, when necessary, the source of wealth, and cooperate with verification requests. Failure to comply may result in restrictions, suspension, or termination of the account.

Account Restrictions, Suspension and Termination

Smvip may suspend or terminate an account or restrict access where compliance with AML/CTF requirements cannot be established, or where the customer engages in behavior indicating potential financial crime or a breach of this Policy. Funds associated with restricted activity may be frozen in accordance with applicable law and shall be released only through lawful channels.

Third-Party Verification and Reliance

Smvip may engage authorized, compliant third-party service providers for identity verification and documentation checks. Such engagements are governed by formal agreements and audit trails to ensure data integrity, accuracy, and legal compliance. Smvip remains responsible for all decisions related to customer due diligence.

Training and Awareness

Smvip provides ongoing AML/CTF training to employees and appointed personnel. Training covers identification of red flags, escalation procedures, recordkeeping, data privacy, and reporting obligations. Training frequency and content are reviewed annually and updated to reflect regulatory changes and emerging risks.

Policy Availability and Amendments

A condensed version of this Policy is available to customers for awareness purposes. The full AML/CTF Policy is maintained by Smvip and is available upon legitimate request to regulators or institutional stakeholders. Smvip reviews and updates this Policy at least annually or in response to material regulatory changes.

Cooperation with Regulators and Authorities

Smvip cooperates fully with competent authorities and regulators in accordance with applicable laws. When required, Smvip provides access to records, transaction data, and related documentation to support investigations and regulatory examinations.

Contact and Support

Questions about this AML/CTF Policy or requests for the full policy may be directed through Smvip’s Compliance Department via the on-site contact form or other official Smvip channels. All inquiries will be handled in accordance with applicable data protection and confidentiality requirements.