Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) Policy

esim5g.com (hereinafter referred to as “the Company”) is a global online platform, incorporated under the laws of the Republic of Estonia, offering digital services such as mobile balance top-ups and gift card purchases. This Anti-Money Laundering, Counter-Terrorist Financing, and Know Your Customer Policy (hereinafter referred to as “the Policy”) aims to prevent the Company from being used for any illegal activities, including money laundering and terrorist financing.

Purpose of the Policy

The Policy has been developed in accordance with both international and local legislation and outlines the internal procedures implemented to detect and prevent:

• Money laundering
• Terrorist financing
• Human and drug trafficking
• Proliferation of weapons of mass destruction
• Corruption and bribery
• Other forms of suspicious or illegal activity

Definitions

Money laundering is defined as the transfer or concealment of property derived from criminal activity in order to disguise its illegal origin or assist someone in evading legal consequences.

Terrorist financing refers to the act of knowingly providing or collecting funds, directly or indirectly, intended to be used in whole or in part for terrorist activities.

Legal Framework

The Company complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and is guided by recommendations from:

• The Joint Money Laundering Steering Group (JMLSG)
• The Financial Action Task Force (FATF), an international inter-governmental body promoting policies to combat money laundering and terrorist financing

Additional applicable legislation includes:

• The 5th Anti-Money Laundering Directive (EU) 2018/843
• The Anti-Terrorism Acts of 2000 and 2001
• The Counter-Terrorism Act 2008
• The Financial Conduct Authority (FCA) Handbook

Risk-Based Approach

The Company adopts a risk-based approach to AML/CTF and KYC compliance. This includes assessing the level of risk posed by each user and applying appropriate measures to mitigate identified risks. The approach ensures that prevention efforts are proportionate to the actual level of risk.

Implemented Measures

To enforce this Policy, esim5g.com has implemented the following controls:

• Development and application of a formal KYC policy
• Customer due diligence procedures and enhanced due diligence for high-risk users
• Tiered user verification based on risk level
• Cooperation with law enforcement and regulatory authorities
• Reporting of suspicious activity
• Integration of anti-fraud detection systems
• Regular training for all staff on AML/CTF compliance

User Verification Procedures

To comply with AML/CTF requirements, esim5g.com has established a multi-level user verification process:

1. Identity Verification: Users must provide personal details and a digital copy of their valid international passport or national ID.
2. Selfie Verification: Users are required to upload a photo of themselves holding the document near their face for visual comparison.
3. Payment Card Verification (if applicable): If a user chooses to pay by bank card, they must submit card details via a secure form and upload a photo of themselves holding the card near their face. The middle 8 digits of the card number must be concealed.

Policy Language

This AML Policy is written in English and may be translated into other languages for convenience. In the event of any discrepancies between the translated version and the English version, the English version shall prevail.