Last Updated: 6th May 2025

1. Purpose
This policy outlines the measures Enkel Pay intends to implement to comply with global Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations. Our goal is to prevent our platform from being used for money laundering, terrorism financing, or illicit activity.

2. Scope
This policy will apply to:
• All users of Enkel Pay (businesses and individuals)
• All transactions processed via our platform
• All employees and partners with access to customer data

3. KYC Requirements (To Be Enforced Upon Launch)
Before enabling payment functionality, all users will be required to complete identity verification, including:
• Full legal name
• Date of birth (for individuals) / Company registration details (for businesses)
• Proof of address
• Government-issued ID
• UBO verification for companies and entities

4. Ongoing Monitoring (Planned)
We will implement continuous monitoring for:
• Unusual or suspicious activity
• Sudden changes in transaction volume or behavior
• Blacklisted countries or high-risk jurisdictions

Suspicious activity will be flagged and, where applicable, reported to relevant regulatory bodies (e.g. AUSTRAC, FMA, ACIC).

5. Risk-Based Approach
Users will be assigned a risk rating at onboarding, influencing:
• Level of due diligence required
• Transaction thresholds
• Frequency of ongoing review

6. Record Keeping
We will securely store all KYC documents and audit trails for a minimum of 7 years, in compliance with applicable regulations.

7. Staff Training
All Enkel Pay staff involved in handling customer data will be required to complete regular AML/KYC awareness training (to be implemented pre-launch).

8. Policy Review
This policy will be reviewed periodically and updated as required to ensure compliance with all applicable laws and partner obligations.

📌 Note: This is a placeholder policy indicating our commitment to compliance. Final versions will be reviewed and approved by legal and regulatory advisors prior to launch.