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AML Policy

1. Purpose of Policy

This Anti-Money Laundering and Counter-Terrorism Financing Policy (“Policy”) outlines controls enforced by Nezenx Pte. Ltd. (“Company”) to detect, prevent, and report money laundering, terrorist financing, sanctions violations, and other unlawful financial activities.

The Company complies with requirements of the Monetary Authority of Singapore (MAS), relevant sanctions authorities (e.g., OFAC), and international standards established by the Financial Action Task Force (FATF).

2. Risk-Based Approach

The Company adopts a risk-based approach (RBA), applying enhanced monitoring and additional screening where users, merchants, funding sources, or MCC categories indicate heightened exposure to AML/CFT risks.

3. Know-Your-Customer (KYC) Measures

3.1 All Users must complete identity verification before activation of Virtual Cards.

3.2 KYC records may include:

  • Government-issued identity documents
  • Business registration certificates
  • Proof of address
  • Proof of advertising activity or business purpose if required
  • Source of funds documentation

3.3 Any failure to provide requested information may delay onboarding or result in denial of services.

4. Ongoing Monitoring

The Company performs continuous monitoring of User activities including:

  • transaction patterns
  • decline ratios
  • chargeback frequency
  • suspicious or abnormal MCC usage
  • geolocation and velocity checks

Abnormal patterns may trigger suspension pending review.

5. Sanctions Compliance

Services are not available to individuals or entities:

  • located in OFAC-sanctioned jurisdictions
  • identified as FATF High-Risk / Blacklist
  • operating from non-cooperative, non-KYC regions
  • (Full list in Annex B of Terms & Conditions)

Users must not indirectly interact with restricted jurisdictions through sub-accounts or third parties.

6. Enhanced Due Diligence (EDD)

High-risk Users may require additional screening, including:

  • business justification statements
  • ads platform account verification
  • spending pattern transparency
  • beneficial ownership declarations

EDD may be performed periodically throughout service usage.

7. Suspicious Activity Reporting

The Company may investigate, block, freeze, or report suspicious activity to:

  • MAS regulatory authorities
  • card network risk teams
  • law enforcement where required

Users are not entitled to disclosure of investigative details.

8. Record Retention

KYC and transactional data will be securely retained for a minimum period required under Singapore law and MAS guidance, including for potential audits, inquiries, or disputes.

9. User Responsibilities

Users agree to:

  • provide only truthful and accurate data
  • use Virtual Cards for legitimate business purposes
  • avoid prohibited categories (Annex A — T&C)
  • cooperate with all investigation requests

Non-compliance may result in immediate termination without refund.

10. Amendments

This Policy may be updated at any time. Continued use of the Platform constitutes acceptance of the revised version.

11. Contact

  • legal@nezenx.com
  • NEZENX PTE. LTD.
  • 10 Anson Road #33-10, Suite C, International Plaza, Singapore 079903