Mulltta is owned and operated by Mulltta PTE LTD ("Mulltta", "Company", "we", "us", and "our"). It is our policy to prohibit and prevent money laundering, and any activity that might facilitate money laundering or the funding of terrorist or criminal activities.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Terrorist financing may not involve proceeds of criminal conduct but is rather an attempt to conceal either the origin of the funds or their intended use.
Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same or similar to methods used by other criminals to launder funds. Funding for terrorism does not always require large sums of money and the associated transactions may not be complex.
Our Anti-Money Laundering (AML) policies, procedures and internal controls are designed to ensure compliance with all applicable regulations, rules and laws. We periodically review and updated our policies, procedures and internal controls to ensure continued regulatory compliance.
The Company operates in compliance with AML and Know Your Customer (KYC) rules and regulations in the jurisdictions it operates in or sells products or services to and has developed the given KYC and AML Policy to protect itself from involvement in money laundering or suspicious activity as follows:
- The Company has established KYC and AML policies and procedures that have been reviewed and approved by the Company's Board of Directors (the "Board").
- The Company is implementing internal controls throughout its operations designed to reduce risks of money laundering, including designating a person responsible for AML compliance.
1. Purchaser Identification
The Company collects identifying information on purchasers. The Company shall collect the following information about each purchaser:
- Full Name
- Country of Residence
- Email address
- Copy (front and back) of ID
- Data collected from ID: Date of birth, Nationality, ID scan
- A Description of Source of Funds
- PEP checks
- Adverse Media checks
- Company Name
- Company Address
- Description of Business Activities
- Government-issued business registration number or tax identification number
- Authorized Representative details
After completion of the KYC/AML process, the Company may require additional documentation which will be included in our purchaser identification process.
- The Company shall not accept purchasers (individuals or entities) who are not at least eighteen (18) years of age.
- The Company shall not accept purchasers from the countries sanctioned by Singapore, the USA and the European Union - Individuals or entities from or residing the sanctioned countries (the "Prohibited Purchasers").
- The restricted countries are subject to change and include: Afghanistan, Iran, North Korea, Sudan, Syria.
3. KYC/AML Screening
The Company shall screen prospective purchasers for matches in the following categories:
- Global Sanctions List - Screening prospective purchasers against sanctions lists.
- PEPs - Screening prospective purchasers for identification as a "Politically Exposed Person". A PEP is a term describing someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they could hold.
- Adverse Media - Screening prospective purchasers against adverse media involves looking for any negative mentions of them in traditional news media and publicly available information more broadly. Any prospective purchaser that has a match on any of the above categories shall be flagged and blocked pending review by the Company and its counsel of the flag.
4. Dispositions of Flags
- Global Sanctions List - If the flag is a match on the Global Sanctions List, the Company shall seek clarifications from the individual/company to further establish their identity and ensure misidentification has not occurred. If the hit is confirmed, the purchaser will be denied and contacted to let them know of the disposition of the review.
- PEPs - If the flag is a match on PEPs, the Company's council shall review the AML report and may request additional verification from the prospective purchaser. After receiving any additional verification information, the Company may provide the prospective purchaser with notice of disposition.
- Adverse Media - If the flag is a match on Adverse Media, the Company's counsel shall review the adverse media may request additional verification from the prospective purchaser. After receiving any additional verification information, the Company may provide the prospective purchaser with notice of disposition.
5. Process Management
The duties of the AML Compliance Person will include monitoring the Company's compliance, overseeing communication and training for employees.
The AML Compliance Person will also ensure that the Company keeps and maintains all of the required AML records and will ensure that suspicious activity reports are filed. The AML Compliance Person is vested with full responsibility and authority to enforce the Company's AML program.