AML/KYC Policy for Buyers (International)

This policy outlines the Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures for ValuecardThailand. Our goal is to ensure strict compliance with international AML/CFT standards, including the recommendations of the Financial Action Task Force (FATF), and all applicable local laws in the jurisdictions we operate. We are committed to providing a secure and transparent platform for purchasing gift vouchers.

Purpose

This AML/KYC policy is designed to prevent our platform from being used for money laundering, terrorist financing, fraud, or other illicit activities. We implement a risk-based approach globally to maintain a secure and trustworthy environment for all our buyers.

Applicability

This policy applies to all individuals and entities ("Buyers") using our services.

Verification requirements are risk-based and scaled according to transaction volume, activity, and the buyer's geographic location.

1.Registration and Basic Verification (Mandatory for All Buyers)

To access our platform, all Buyers must:

• Register an Account: Provide a valid email address, full legal name, and phone number.
• Confirm Legal Capacity: Buyers must confirm they are over the age of 18 (or the age of majority in their country of residence) and have the legal capacity to enter into a contract.
• Complete OTP Verification: All accounts must be verified using a One-Time Password (OTP) sent to the registered phone number or email address.
• Agree to AML/KYC Terms: Acknowledge and agree to abide by this AML/KYC policy during registration.

2.Stage 1: Purchases Under € 2,900 Per Month

For Buyers whose monthly purchases total € 2,900 or less, the following requirements apply:

• Account Verification Only: No need to upload photo ID or additional documents at this stage.
• Daily Purchase Limit: Transactions are capped at € 800 per day.
• Prohibited Regions: Purchases are automatically blocked from individuals or entities residing in, or acting on behalf of, jurisdictions identified as high-risk by the FATF, EU, OFAC, or other relevant international bodies. This includes, but is not limited to:

1. Countries under international sanctions (e.g., Iran, North Korea).
2. Jurisdictions on the FATF "Grey List" or "Black List".

3. Stage 2: Purchases Over € 2,900 Per Month

For Buyers whose monthly purchases exceed € 2,900, enhanced Customer Due Diligence (CDD) is required:

• For Individual Buyers:

1. Photo ID Submission: Upload a clear copy of a valid, government-issued photo ID (e.g., passport, national ID card).
2. Proof of Address: Submit a recent utility bill, bank statement, or government correspondence (dated within the last 3 months) showing the Buyer's name and residential address.

• For Corporate Buyers:

1. Certificate of Incorporation: Proof of business registration.
2. Register of Directors and Shareholders: Documentation identifying the beneficial owners (any individual owning or controlling more than 25% of the shares or voting rights) and directors.

• Document Verification: Our compliance team will review and approve all submitted documents before enabling higher purchase limits.

4.Transaction Monitoring and Restrictions

• Daily Purchase Limit: No single Buyer may purchase more than € 800 worth of vouchers in a 24-hour period without enhanced verification.
• Monthly Thresholds: Buyers who reach € 5,000 in cumulative purchases within a calendar month will be required to complete Stage 2 enhanced verification to continue purchasing.
• Geographic Restrictions: Transactions originating from or linked to prohibited jurisdictions will be automatically blocked and reported to the relevant financial intelligence units (FIUs).

5.Suspicious Activities and Account Actions

ValuecardThailand monitors transactions for suspicious activity and reserves the right to:

• Request Additional Documentation: We may request further information or documentation at any time to verify a Buyer’s identity, the source of funds, or the legitimacy of their transactions.
• Freeze Accounts: Accounts may be temporarily frozen if flagged for suspicious activity, pending further review.
• Hold Funds/Orders: Transactions may be suspended and held if severe suspicion or confirmed fraudulent activity is identified, pending investigation.
• Report to Authorities: We are obligated to report suspicious transactions to the relevant national Financial Intelligence Unit (FIU) without prior notice to the Buyer, in accordance with international and local regulations.

Examples of suspicious activities include, but are not limited to:

1. Unusual or inconsistent transaction patterns (e.g., rapid, high-value purchases).
2. Attempts to use fake, forged, or invalid documentation.
3. Use of VPNs or proxies to obscure geographic location.
4. Transactions that appear structured (smurfing) to avoid verification thresholds.

6.Prohibited Activities

Buyers are strictly prohibited from:

• Using fake, stolen, or synthetic identities.
• Attempting to circumvent purchase limits or geographic restrictions.
• Using funds that are the proceeds of crime.
• Engaging in any activity that violates applicable international or local laws.

7.Data Protection and Confidentiality

ValuecardThailand is committed to safeguarding your personal data:

• All collected KYC data is securely stored and processed strictly for regulatory compliance and internal risk management purposes.
• We adhere to major international data protection frameworks, including the GDPR for EU citizens, and ensure all data is handled confidentially and not retained longer than necessary under applicable laws.

8. Reporting and Non-Compliance

• Reporting: We will file a Suspicious Transaction Report (STR) with the relevant FIU when required by law.
• Account Actions: Non-compliance with this policy will result in account suspension, restriction of services, or permanent closure.

9. Processing Time:

Processing time for KYC documentation may take up to 15 working days for level 2 or higher designations. However, in certain circumstances even level 1 can take up to 15 days for processing and review.

10. Policy Updates

This policy will be reviewed and updated periodically to ensure ongoing compliance with changes in international laws and regulations. Buyers will be notified of any material changes.