Anti-Money Laundering & CFT Policy (AML / CFT)

PremLogin strictly complies with Hong Kong's Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), with reference to FATF international standards, the EU Anti-Money Laundering Directives (AMLD) and the applicable laws of the regions we serve. This Anti-Money Laundering (AML) policy details our zero-tolerance stance and internal controls against money laundering, terrorist financing and sanctions evasion.

① Scope

This policy applies to all transactions made through our platform, with enhanced review for the following high-risk scenarios:

• A single transaction of USD 1,000 or more
• Monthly cumulative transactions of USD 3,000 or more
• Large-volume procurement, wholesale and resale partnerships
• Transactions from FATF high-risk or monitored jurisdictions
• Transaction patterns with no apparent economic rationale

② Customer Due Diligence (CDD / KYC)

For users meeting the following conditions, we require different levels of Customer Due Diligence by risk:

Standard KYC (monthly spend ≥ USD 1,000):

• Front image of ID / passport / driver's license
• Proof of address (utility bill, bank statement, within 3 months)
• Real-name phone verification

Enhanced KYC (monthly spend ≥ USD 3,000 or wholesale channel):

• All standard KYC items
• Source-of-funds explanation (salary, business income, investment, etc.)
• Video verification (live identity match)
• Wholesale accounts must provide company registration, tax ID and beneficial-owner information

③ Suspicious-Transaction Monitoring & Reporting

We run a 24×7 automated transaction-monitoring system; the following patterns trigger manual review and reporting to the Hong Kong Joint Financial Intelligence Unit (JFIU) as required by law:

• Multiple people sharing one card or payment account
• Many small transactions by one user in a short time (suspected structuring/smurfing)
• Rapid large transfers with no business relationship
• Transactions from high-risk countries or undocumented shell companies
• One user frequently switching payment methods

④ Sanctions Screening

We never provide service to individuals, entities or countries on the following sanctions lists:

• UN Security Council sanctions list
• U.S. Treasury OFAC (SDN List)
• EU financial sanctions list
• UK OFSI sanctions list
• Hong Kong and other international sanctions lists

All new users and counterparties are automatically screened; matches are frozen and reported immediately.

⑤ Data Retention

To assist regulatory investigations, we retain the following for at least 5 years as required by law:

• KYC documents and identity proof
• All transaction records
• Customer-support conversation records
• Internal review and reporting records

⑥ Internal Controls & Training

• All staff complete annual AML / CFT training
• Independent third parties periodically audit control effectiveness
• We protect staff who report suspicious activity internally

⑦ User Cooperation Obligations

When using our service, you agree to:

• Provide true, accurate and complete identity and transaction data
• Cooperate with our KYC and EDD requirements
• Not help others circumvent this policy
• Respond promptly when we request additional information

For non-cooperation, we reserve the right to refuse service, freeze accounts and report to the authorities.

⑧ Reporting Channel

If you discover suspected money laundering, terrorist financing or fraud on our platform or by others, contact:

• Email: info@premlogin.com (confidential, 24h)
• We keep the reporter's identity confidential