KYC & AML

KYC & AML POLICY

(Know Your Customer & Anti-Money Laundering Policy)

Last Updated: July 2026

1. Introduction

This Know Your Customer ("KYC") and Anti-Money Laundering ("AML") Policy explains the procedures implemented by SULTAN BİLİŞİM TEKNOLOJİLERİ SANAYİ VE TİCARET LİMİTED ŞİRKETİ ("EpinSultan", "we", "our", or "us") to prevent and detect:

Money laundering
Terrorist financing
Fraud
Financial crime
Payment abuse

We are committed to maintaining a secure platform and complying with all applicable legal and regulatory requirements.

2. Company Information

This Policy applies to the services provided by:

SULTAN BİLİŞİM TEKNOLOJİLERİ SANAYİ VE TİCARET LİMİTED ŞİRKETİ

Registered Address:

Gümüşyaka Mah. İkizçınar Sk. No: 9 F

Silivri / İstanbul

Türkiye

Tax Office: Silivri

Tax Number: 7830486445

Email: destek@epinsultan.com

Website: epinsultan.com

3. Risk-Based Approach

We apply a risk-based approach to assess customers and transactions.

Risk categories may include:

Low Risk
Medium Risk
High Risk

Risk assessments may consider factors including:

Country or region
Transaction amount
Purchase frequency
Payment method
Account behavior
Previous transaction history
Fraud indicators

Enhanced due diligence may be applied to higher-risk customers.

4. Customer Identification (KYC)

We reserve the right to verify the identity of our customers.

4.1 Individual Customers

Verification may include:

Full legal name
Date of birth
Government-issued photo identification
Proof of residential address
Selfie or biometric verification where appropriate

4.2 Business Customers

Where services are provided to businesses, we may request:

Certificate of incorporation
Company registration documents
Tax registration information
Director and shareholder details
Ultimate Beneficial Owner (UBO) information
Business address verification

Additional documentation may be requested whenever necessary.

5. Transaction Monitoring

We continuously monitor transactions to identify unusual or suspicious activity.

Monitoring may include:

High-value purchases
Multiple payment attempts
Rapid repeated transactions
Multiple accounts linked to one individual
Unusual payment behavior
Geographical inconsistencies

Monitoring may be performed through automated systems and manual review.

6. Suspicious Activity

We reserve the right to investigate transactions that appear suspicious.

Actions may include:

Requesting additional documentation
Delaying order fulfillment
Holding or rejecting transactions
Temporarily suspending accounts
Permanently terminating accounts where appropriate

Examples include:

Suspected identity theft
Stolen payment methods
Money laundering indicators
Chargeback abuse
False identity information

7. Sanctions and Restricted Jurisdictions

We comply with applicable sanctions laws and regulatory requirements.

Users located in sanctioned or restricted jurisdictions may:

Be denied access to our services.
Be subject to enhanced verification.
Have transactions rejected or blocked.

8. Record Keeping

We maintain records relating to:

Identity verification
Transaction history
Customer communications
Compliance reviews

Records are securely retained for the period required under applicable laws and regulations.

9. Data Protection

Personal information collected during KYC procedures is processed in accordance with our Privacy & Cookies Policy.

We implement appropriate safeguards including:

SSL/TLS encryption
Secure storage
Access controls
Internal confidentiality procedures

10. Reporting Obligations

Where required by applicable law, we may disclose information regarding suspicious activities to:

Competent regulatory authorities
Financial intelligence units
Law enforcement agencies
Courts or other governmental authorities

11. User Responsibilities

Users agree to:

Provide accurate and complete information.
Cooperate with identity verification procedures.
Promptly provide any requested documents.
Refrain from fraudulent or illegal activities.

Failure to comply may result in delayed processing, suspension, or permanent termination of the account.

12. Internal Compliance Measures

To maintain an effective AML compliance program, we implement:

Risk assessment procedures
Fraud detection systems
Transaction monitoring
Internal compliance controls
Periodic policy reviews
Employee awareness and compliance training

13. Policy Updates

We reserve the right to amend this Policy at any time.

Updated versions become effective immediately upon publication on epinsultan.com.

Continued use of the Platform constitutes acceptance of the revised Policy.

14. Contact

For questions regarding this KYC & AML Policy or compliance matters, please contact: