Double J Global Pte. Ltd.
Effective: June 2025
Contact: legal@doublejglobal.com

1. Purpose

This policy outlines Double J Global Pte. Ltd.’s (“the Company”) internal framework for preventing money laundering, terrorism financing, and fraudulent identity misuse. The Company voluntarily adopts this policy to ensure a high level of compliance despite not being a licensed payment institution under the Singapore Payment Services Act (PSA).

2. Regulatory Basis

This policy is structured in accordance with:

• Monetary Authority of Singapore (MAS) AML/CFT Guidelines
• Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
• Terrorism (Suppression of Financing) Act (TSOFA)
• Financial Action Task Force (FATF) recommendations

3. Risk-Based Approach

Double J Global applies a Risk-Based Approach (RBA) to all customer onboarding, transaction monitoring, and partner evaluation processes.

Risk levels are determined based on:

• Customer type (individual vs corporate)
• Country of origin
• Transaction size and behavior
• Prior history or anomalies

Higher risk customers are subject to Enhanced Due Diligence (EDD), which may include additional documentation and verification procedures.

4. Customer Due Diligence (CDD)

a. For Corporate Clients

• Company registration certificate (e.g., ACRA BizFile)
• Articles of Incorporation
• List of directors and UBOs (Ultimate Beneficial Owners >25%)
• Government-issued ID for UBOs
• Description of business activities
• Proof of address for principal place of business

5. Transaction Monitoring

All transactions conducted on the platform are subject to real-time monitoring using a combination of automated and manual controls. Monitoring includes:

• Geolocation mismatches (IP vs billing address)
• High-volume or high-velocity transactions
• Suspicious payment patterns
• Unusual currency behavior or conversion
• Repeated failed attempts or use of blacklisted payment methods

Suspicious transactions are flagged and escalated to the compliance team.

6. Record Keeping

All KYC data and transactional logs are securely retained for a minimum of five (5) years after the end of the business relationship or final transaction date.

These records are made available to regulators, payment partners, or law enforcement upon valid request.

7. Reporting Obligations

While not required to submit Suspicious Transaction Reports (STRs) to MAS, the Company maintains an internal escalation system.

If a transaction or customer behavior is deemed high-risk or suspicious:

• The case is escalated to the Compliance Officer
• Access to the platform may be temporarily suspended
• Documentation is retained for future reference
• A voluntary disclosure to law enforcement may be made if applicable

8. Governance and Training

• A designated Compliance Officer is responsible for all AML/KYC matters
• All relevant staff receive annual AML/KYC training
• New employees undergo onboarding training prior to handling sensitive customer data
• Compliance procedures are tested and reviewed periodically

9. Review and Amendments

This AML/KYC Policy is reviewed annually or following any major legal, business, or operational changes. All updates are approved by management and published to relevant stakeholders.