Anti-Money Laundering (AML) Policy

1. Purpose

Octopus Cards LLC ("Octopus Cards") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines the principles, procedures, and controls we maintain to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

2. Scope

This policy applies to all employees, officers, contractors, partners, and agents of Octopus Cards, as well as all users and business clients of our platform. It covers all products and services offered, including digital gift cards, mobile top-ups, utility vouchers, and AI platform credits.

3. Know Your Customer (KYC)

We implement risk-based KYC procedures to verify the identity of our customers and business partners:

• Individual Users: We may require government-issued identification, proof of address, and other documentation for transactions above certain thresholds or when suspicious activity is detected.
• Business Partners: We conduct due diligence on all business partners, including verification of company registration, beneficial ownership, and regulatory compliance.
• Ongoing Monitoring: Customer information is reviewed and updated periodically. Enhanced due diligence is applied to high-risk customers and transactions.

4. Transaction Monitoring

We employ automated and manual monitoring systems to detect suspicious transaction patterns, including but not limited to:

• Unusually large or frequent purchases of digital cards.
• Rapid purchasing and redemption patterns.
• Transactions inconsistent with a customer's known profile.
• Purchases from high-risk jurisdictions.
• Attempts to structure transactions to avoid reporting thresholds.

5. Reporting Obligations

When suspicious activity is identified, we file reports with the appropriate financial intelligence units and regulatory authorities in accordance with applicable laws. All employees are trained to recognize and escalate potential suspicious activities. We maintain records of all reports filed and cooperate fully with law enforcement investigations.

6. Sanctions Compliance

Octopus Cards screens all customers and transactions against applicable sanctions lists, including those maintained by the United Nations, the European Union, OFAC (U.S.), and other relevant authorities. We do not conduct business with sanctioned individuals, entities, or countries.

7. Record Keeping

We maintain comprehensive records of all customer identification documents, transaction records, and suspicious activity reports for a minimum of 5 years after the end of the customer relationship or the completion of the transaction, whichever is later.

8. Employee Training

All employees and relevant contractors receive regular AML training covering the recognition and reporting of suspicious activities, KYC procedures, and regulatory updates. Training records are maintained and updated annually.

9. Compliance Officer

Octopus Cards has designated a Compliance Officer responsible for the implementation and oversight of this AML policy. The Compliance Officer reports directly to senior management and is responsible for ensuring the company's adherence to all applicable AML laws and regulations.

10. Policy Updates

This policy is reviewed and updated at least annually, or more frequently as required by changes in applicable laws, regulations, or business practices.

11. Contact Us

To report suspicious activity or for questions about this policy, contact us at:

Octopus Cards LLC
Email: compliance@octopuscards.io