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Anti-Money Laundering Policy

What is Money Laundering?

Money laundering is a process intended to mask the benefits derived from a predicate criminal activity so that funds appear to have originated from a legitimate source. These funds often enter the financial system through institutions such as banks, fund houses, trust companies and corporate service providers.

Generally, the process of money laundering comprises of three stages, during which there may be numerous transactions that could alert a financial institution to money laundering activity:

  1. Placement: the physical disposal of benefits derived from the predicate criminal activity;
  2. Layering: the separation of benefits derived from the predicate criminal activity from their source by creating layers of financial transactions designed to disguise the audit trail; and
  3. Integration: the provision of apparent legitimacy to benefits derived from the predicate criminal activity. If the layer process succeeds, integration schemes place the laundered funds back into the economy so that they re-enter the financial system appearing to be legitimate business.

Money laundering is a serious offence. In law, it is regarded as being almost as serious as the offence which generated the criminal process. It should be kept in mind that where an employee assists a client to place, layer or integrate illegal funds that employee may have engaged in the act of money laundering. If an employee turns a blind eye where they believe a client is involved in laundering the proceeds of crime, that employee could be charged with assisting in laundering the proceeds of crime.

Policies and Procedures

The Policy will be approved by the Company’s Board. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.

AML Compliance Officer

The Company has a Compliance Officer to be responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Officer will have a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Officer will be responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company’s Board.

Net Marketing Services’ Anti-Money Laundering Policy

Net Marketing Services is currently regulated by the Monetary Authority of Singapore (MAS) under the Payment Services Act as an exempted entity. We are allowed to continue our business operations - under Net Marketing Services Pte Ltd - in Singapore, until the official licenses under the Payment Services Act are issued.

As a matter of policy, Net Marketing Services has adopted procedures which require its Senior Management and officers to:

  • conduct its business in conformity with high ethical standards, and guard against establishing any business relations or undertaking any transaction, that is or may be connected to money laundering or terrorist financing; and
  • wherever possible, to the fullest extent possible, assist to corporate with law enforcement authorities to prevent money laundering and terrorism financing.
  • perform enhanced due diligence on higher risk customers, including those who are assessed to be politically exposed persons;
  • prohibit dealing with certain categories of clients, including but not limited to:
    • Individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists;
    • Clients operating in prohibited industries;
    • Client in which their identity, or beneficial owners cannot be ascertained;
    • Clients who refuse to furnish information or documents sufficient to satisfy our due diligence;
    • Clients where the legitimacy of the business cannot be ascertained.

Net Marketing Services will conduct their due diligence on all customers by performing KYC checks where we will obtain information like:

  • Photo ID (Identification Card/Driver’s License/Passport)
  • Income Proof
  • Purpose of buying
  • Source of funding
  • Digital wallet address and verification of its ownership

The following are examples of verification methods Net Marketing Services may use:

  • Obtaining proof of address, such as a copy of a Utility Bill/Telephone Bill/Bank Statement
  • Obtaining a financial statement for a business account
  • Comparing the identifying information with information available from a trusted third party source
  • Photo ID of the shareholders or the directors of a corporate client

Net Marketing Services strictly does not allow third-party transfers (buying/selling on behalf of someone else). Net Marketing Services will only deal with customers who are using a local Singapore Bank account to make or receive payments.

Net Marketing Services keeps tabs on various online investment scams through the news and communications to protect their customers from fraud. The objective of this is to ensure that the customers of Net Marketing Services understand the risks of cryptocurrency investment and online scams and to protect them. Net Marketing Services will not proceed with orders associated with such scams. Where required, Net Marketing Services will make a suspicious transaction report.

Suspicious Transaction and Activity Report

Net Marketing Services will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary.

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.

The Compliance Officer will initially make the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, he or she will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

AML Policy Audit

Licensed payment service providers are required to have in place adequate independent audit arrangements to regularly assess adequacy and the effectiveness of its procedures, controls and its compliance with regulatory requirements.

In addition, with regards to Anti-Money Laundering/Countering Financing of Terrorism controls, licensed payment service providers must maintain an audit function to assess the effectiveness of its internal policies, procedures, controls and adherence to regulatory requirements.
Net Marketing Services will go for an Independent Audit to review and assess the compliance with the AML/CFT framework.

What is Travel Rule?

The Financial Action Task Force introduced the Travel Rule in June 2019 to prevent terrorists and other criminals from having unrestricted access to wire/crypto transfers for moving their funds, and to detect such misuse when it occurs. The purpose of Travel Rule is to ensure that basic information on the originator and beneficiary of wire/crypto transfers is collected and made readily available. The information collected will help AML/CFT efforts by enabling financial authorities to detect and prevent money laundering activities that involve cryptocurrencies.

Information required for Travel Rule

When you make a Buy Order on our platform, you will be required to provide us with your wallet address and the source of the wallet (private wallet - Trust Wallet/Metamask etc. OR exchange wallet – Binance/Huobi/FTX etc.). Your wallet address and wallet source, together with the Personal Information you provided during your Account Verification will be submitted to other VASP (Virtual Asset Service Providers) for us to comply with the Travel Rule requirements.

By making an order, you acknowledge and agree to allow us to provide our Travel Rule service provider with your personal information mentioned above.


The Monetary Authority of Singapore (MAS) requires Net Marketing Services Pte Ltd to provide this risk warning to you as a customer of a digital payment token (DPT) service provider. Before you pay your DPT service provider any money or DPT, you should be aware of the following.

  1. Your DPT service provider is exempted by MAS from holding a licence to provide DPT services. Please note that you may not be able to recover all the money or DPTs you paid to your DPT service provider if your DPT service provider’s business fails.
  2. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.
  3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
  4. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.
  5. I understand the Risk of Online Investment using cryptocurrencies. If I lose anything in my Investment, I will not hold liable the seller and undersigned for any losses incurred by myself.

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