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Anti-Money Laundering (AML) Policy

okePay Asia Ltd. · Last updated: June 2026

okePay Asia Ltd. ("okePay", "we", "us") is committed to preventing money laundering, terrorism financing, and any activity that supports or facilitates such conduct. This policy describes the framework we use to detect, prevent, and report financial crime across our payment-orchestration platform.

1. Scope

This AML Policy applies to all merchants, partners, employees, contractors, and counterparties interacting with okePay services, including the okePay vPOS, Paylink, and merchant dashboard products.

2. Customer Due Diligence (CDD) & KYB

Every prospective merchant completes a Know-Your-Business (KYB) questionnaire before going live. We collect and verify business registration documents, beneficial-owner identification, proof of operating address, director ID, and the merchant's traffic-area distribution and requested payment methods. Higher-risk verticals are subject to enhanced due diligence.

3. Ongoing Monitoring

Settled and pending transactions are monitored for unusual patterns: structuring, rapid movement of funds, mismatched geographies, sanctioned counterparties, and abnormal velocity. Alerts are reviewed by our compliance team and escalated where required.

4. Sanctions & PEP Screening

okePay screens merchants, beneficial owners, and material counterparties against applicable sanctions lists (including OFAC, EU, UN, HKMA) and politically-exposed-person (PEP) databases at onboarding and on a continuous basis.

5. Reporting

Where the threshold is met, suspicious transactions are reported to the Hong Kong Joint Financial Intelligence Unit (JFIU) and to any other competent authority required by applicable law. We do not "tip off" the subject of any report.

6. Record Keeping

Transaction records, KYB files, monitoring alerts, and SAR filings are retained for at least seven years from the closure of the merchant relationship.

7. Training

All okePay personnel with customer-facing or transaction-handling responsibilities complete AML training at onboarding and annually thereafter. The Money Laundering Reporting Officer (MLRO) is responsible for keeping the program current with regulatory change.

8. Contact

For AML-related questions or to report a concern, contact the okePay Compliance team at compliance@okepay.biz or by post to:

okePay Asia Ltd.
3303 Cable TV Tower, 9 Hoi Shing Road,
Tsuen Wan, NT, Hong Kong