AML Policy

POLICY ON PREVENTION OF LAUNDERING PROCEEDS OF CRIME AND FINANCING OF TERRORISM

ARTICLE 1- COMPANY

ALLPAY Transfer Bilişim ve Yazılım A.Ş. is a digital wallet and mobile payment company established under the laws of the Republic of Turkey and continues its commercial life in full compliance with the laws.

ARTICLE 2- DEFINITIONS and ABBREVIATIONS

In this Anti-Money Laundering and Countering the Financing of Terrorism Policy;
Policy: This Policy on Prevention of Laundering Proceeds of Crime and Financing of Terrorism
Company/ALLPAY: ALLPAY TRANSFER BİLİŞİM VE YAZILIM A.Ş.
Site: refers to the platforms managed by the Company, including all web pages, web applications, application programming interfaces (APIs) and mobile applications offered through the website www.allpaytr.com.
User: Within the scope of the Policy, the real person who is a member of the Platform and benefits from the services offered on the Platform and accepts the matters in this Policy in return,
KYC: Customer identification and verification.

ARTICLE 3- PURPOSE

The purpose of this Policy on Prevention of Laundering Proceeds of Crime and Financing of Terrorism is to reduce risk by evaluating users, transactions and services within ALLPAY with a risk-based approach, to prevent the creation of an environment that facilitates the laundering of proceeds of crime and the financing of terrorism, to raise awareness and information of employees in this direction, and to inform the User that the Company carries out its activities in accordance with the applicable legislation, especially the Law No. 5549 on the Prevention of Laundering Proceeds of Crime and the Law No. 6415 on the Prevention of Financing of Terrorism.
In this context, ALLPAY follows international and local policies and legal regulations that are elements of the global fight against Laundering Proceeds of Crime and Financing of Terrorism and carries out its activities in compliance with legal regulations.
At the same time ALLPAY,
Maintain the reputation and trust that its own brand carries,
Recognizing the customers with whom they establish a service relationship and being selective when establishing a service relationship,
To prevent the Site from turning into an environment that facilitates the laundering of criminal proceeds and the financing of terrorism by monitoring the transactions carried out by users,
Ensuring that its employees are aware of and in compliance with legal regulations and internal policies and principles on the prevention of Laundering Proceeds of Crime and Financing of Terrorism,
It aims to identify, rate, monitor and evaluate the risks to which it may be exposed and to establish the necessary mechanisms to eliminate or manage the risks.

ARTICLE 4- RISK ANALYSIS AND MONITORING

The purpose of Risk Analysis, Monitoring and Control activities is to protect, monitor and control the Company and the cryptocurrency trading platform against risks.
ALLPAY adopts a risk-based approach in monitoring the financial activities of its Clients and in order to prevent laundering proceeds of crime and financing of terrorism, ALLPAY may conduct risk analysis using the following methods and monitor the relevant Clients within the framework of the information obtained as a result of this analysis.

ARTICLE 5- CUSTOMER IDENTIFICATION and VERIFICATION (KYC)

The formal identification of Customers when entering into commercial relationships is a vital element for both anti-money laundering regulations and KYC policy.
In this context, ALLPAY
Requests the contact information of customers prior to the establishment of a transaction.
Identifies the target of the User's transactions (the private or legal person who benefits as a result of the transaction) when necessary.
Monitor the User's use of the service and the transactions carried out by the User.
It takes measures against suspicious Users or transactions.
By ALLPAY
In the control carried out, persons or entities reported by local and international official organizations to be engaged in illegal activities, in particular Laws No. 5549 and 6415 and related legislation, or Persons who are known to be involved in any financial crime, in particular money laundering or financing of terrorism, or
User accounts found to be used in connection with betting and gambling and/or users found to be related to these accounts
membership is not accepted and, where necessary, membership is terminated.
The following are the determinations that ALLPAY must make as a minimum within the scope of standard customer identification measures:
Screening clients for the risk of being included on international sanctions lists (including country risk assessment),
Investigating whether the client and its related parties are associated with very high-risk countries recognized under international sanctions and ALLPAY Internal Policies,
Determining whether someone else is acting on behalf of and/or on account of another person,
Monitoring customer transactions to detect unusual transactions,
Identification and confirmation of the source of income,
Receiving information about the reasons for working with our company.
As a result of the risk assessment to be carried out during customer acceptance or afterwards, ALLPAY shall also apply enhanced customer measures for customers deemed to be risky by ALLPAY. Regardless of the result of the risk assessment, increased measures and/or updated monitoring activities may be considered within the framework of risky customer/transaction/sector assessments within the scope of national and international legislation and current company practices.
Users whose accounts are under review or temporarily or permanently suspended due to any of the criteria in any of the above articles may be subject to change and their status may be changed by ALLPAY at any time, upon the necessity to be seen.

ARTICLE 6- TRAINING, SUPERVISION AND CONTROL

ALLPAY conducts all kinds of controls and audits in accordance with the above-mentioned basic principles and rules. In this context, all kinds of actions are taken against suspicious transactions detected during the audits.
ALLPAY provides the necessary training to its personnel in order to implement the necessary audits and controls at the maximum level. Within this framework, personnel are informed about the definition and introduction of MASAK, internal suspicious transaction reporting channels, the concepts and legislation on laundering proceeds of crime and financing of terrorism, identification of the stages and methods of laundering proceeds of crime and case analyses in this regard, risk areas, and principles regarding customer verification.
ALLPAY regularly prepares reports on laundering proceeds of crime and terrorist financing activities through the internal audit mechanism and this report is submitted to the Board of Directors.
A suspicious transaction is any information, suspicion or reason to suspect that the assets subject to the transaction made or attempted to be made in or through ALLPAY have been obtained illegally or used for illegal purposes, including for terrorist acts or used by terrorist organizations, terrorists or terrorist financiers, or are related or connected to them. The definition of suspicious transaction includes not only the illegal acquisition of the assets subject to the transaction, but also their use for illegal purposes, thereby aiming to prevent the financing of terrorism (including its connection).
ALLPAY manages the processes related to the obligation to provide information and documents pursuant to the legal legislation in accordance with Articles 31, 32 and 33 of the "Regulation on Measures to Prevent Laundering Proceeds of Crime and Financing of Terrorism" and takes the necessary measures.
ALLPAY shall keep the documents relating to its obligations (including training and internal audit) and transactions in all kinds of media (including training and internal audit) for a period of ten years from the date of issue, books and records for a period of ten years from the date of the last entry, and documents and records relating to identification for a period of ten years from the date of the last transaction (the retention periods specified by special laws shall apply separately) and shall submit them to the authorities upon request.

ARTICLE 7- FINAL PROVISIONS

This Policy is an annex and integral part of the User Agreement currently in force between ALLPAY and the User. This policy text is subordinate to and valid together with the main agreement. No provision of the Policy may be interpreted separately or differently from the Agreement, and in case of any conflict between the two texts, the User Agreement shall prevail.
ALLPAY may change the content of this Policy whenever it deems necessary. The updated Policy shall enter into force on the date it is published on the Website. In case of any dispute, ALLPAY's records alone shall prevail and shall be binding on the Users.