Anti-Money Laundering Policy

Introduction

As a company, we understand the importance of preventing money laundering and terrorist financing and adhere to carrying on business in accordance with the highest standards of anti-money laundering and terrorist financing in every country where Jupit operates.

Jupit Digital Service Ltd, as a FinTech company, is subject to the regulatory framework designed to prevent money laundering in each country where we operate. This framework includes such laws as: Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regulations, legislation and guidelines.

To meet this commitment, Jupit Digital Service Ltd has put in place robust policies and procedures. This policy sets forth the company's expectations for its users, employees, and other business partners in every country where we have a presence. We are committed to ensuring that we comply with all applicable laws, regulations and guidelines to prevent money laundering and terrorist financing.

Our Policy Statement on AML and CTF

Jupit Digital Service Ltd have users in various countries and is committed to complying with all Anti-Money Laundering (AML) and Combating Terrorist Financing (CTF) Laws applicable to our presence in each country. It is our policy to only conduct business with users and partners who are involved in legitimate business activity and whose funds are derived from legitimate sources.

Our Policy is designed to prevent money laundering, which includes implementing adequate systems and controls to mitigate the risk of our company being used to facilitate financial crime. We aim to educate our users and employees about AML and CTF Laws and support them in making informed decisions that align with our corporate position as stated in this Policy.

Who is subject to this Policy?

This Policy is applicable to all individuals and entities operating under the Jupit Digital Service Ltd umbrella, including subsidiaries and affiliates. It is binding on all directors, employees, users, and third parties acting on behalf of the company, regardless of their position or role within the organization.

What is Money Laundering and Terrorist Financing?

Money laundering refers to the process of disguising the illegal origin of criminal proceeds. This can involve activities such as cleaning money generated from drug trafficking, Cyber-fraud, or terrorist funding to appear as if it came from legitimate sources.

Terrorist financing involves providing, depositing, distributing, or collecting funds, directly or indirectly, that are intended to be used for committing terrorist acts.

I. Transferring funds to a Jupit account with the knowledge or suspicion that the funds are derived from criminal or specified unlawful activities for the purpose of disguising their illicit origin.

II. Conducting exchange transactions involving criminally acquired funds.

III. Concealing or disguising the true nature, source, disposition, transfer, rights with respect to ownership or control of criminal funds.

IV. Promoting the carrying on of unlawful activities.

V. Participating in, associating to commit, attempting to commit, aiding, abetting, facilitating, or counseling the commission of any of the actions mentioned in the above points.

This policy applies to all Jupit's operations, including all legal entities owned or controlled by Jupit, and to all directors, employees, users, and other third parties acting on behalf of the foregoing.

Possible Financial Crimes

  • Insufficient, false, or suspicious information provided by a user or reluctance to provide complete information.
  • Payment methods or volumes that are not consistent with the payment policy or that are not customarily used in the course of business, such as cash deposits by third parties, payments with cheques/checks, or payment transfers from unrelated third parties.
  • Structuring transactions to avoid government reporting or record-keeping requirements.
  • Wire transfer activity that is not consistent with the activities of the customer, or which originates or terminates with parties unrelated to the transaction.
  • Unexpected spikes in a customer's activities.

If any of these red flags are present, Jupit Digital Service Ltd employees, users, or other third parties acting on behalf of Jupit must report them in line with our AML and CTF Policy.

Who is subject to this Policy?

This Policy is applicable to all individuals and entities operating under the Jupit Digital Service Ltd umbrella, including subsidiaries and affiliates. It is binding on all directors, employees, users, and third parties acting on behalf of the company, regardless of their position or role within the organization.

Repercussions of Violating AML Laws

Failure to comply with Anti-Money Laundering laws can result in serious civil and criminal penalties. This may include significant fines, imprisonment, being blacklisted, extradition, and the termination of business operations. In addition, non-compliance with AML laws can have far-reaching consequences, such as reputation damage, impaired business relationships, limitations on our ability to conduct business, and the considerable expense and time required for internal investigations and defense against government investigations and enforcement actions.

Compliance Controls

As part of our commitment to fostering a culture of compliance and implementing strong controls to abide by AML laws and regulations, we are committed to preventing, detecting, and responding to potential risks associated with money laundering and terrorism financing activities. Jupit places great emphasis on ensuring that all employees and users fully comprehend the severe implications of non-compliance, including the serious consequences that may arise as a result of violating AML laws and regulations.

Know Your Customer (KYC) Procedures

Jupit Digital Service Ltd is fully committed to complying with all applicable anti-money laundering regulations. To achieve this goal and prevent money laundering and terrorist financing, we have implemented customer Due Diligence “DD” processes and procedures in our Line of Businesses (LOBs) based on the "Know Your Customer" principles that includes:

  • Collecting and validating customer personal details during account opening
  • Verifying bank verification numbers Verifying validity of government-issued identity cards
  • Biometric selfie for ownership verification.

In addition, we may conduct enhanced due diligence procedures for customers deemed to pose a higher risk, such as those conducting large or frequent transactions. If any unusual activity is detected during the customer due diligence process or customer engagement, it must be immediately reported to Jupit's designated Compliance or Commercial department.

Applicable Regulatory Framework

Jupit is dedicated to adhering to AML/CTF laws and regulations that are applicable, including the Financial Action Task Force (FATF) recommendations, as well as any other relevant local AML regulations.

Non-compliance

Jupit takes violations of its AML policy seriously and reserves the right to take appropriate disciplinary action against any employee or customer who breaches the policy. This action is independent of any other penalties resulting from the violator's behavior. To ensure compliance with AML laws, the Internal Audit team will conduct regular checks on Jupit's business operations.

Updates, Review and Ownership

Jupit reserves the right to update this Policy periodically, and any revised versions of the policy will be promptly published on the Jupit website.