KYC & AML

KYC & AML POLICY (Know Your Customer & Anti-Money Laundering)

(Last Updated: April 2026)

1. Introduction

This KYC & AML Policy outlines the principles and procedures adopted by epinsultan.com to prevent and mitigate risks related to:

  • Money laundering
  • Terrorist financing
  • Fraud and financial crime

We are committed to maintaining the highest standards of compliance and security.

2. Company Structure

EpinSultan operates through affiliated entities including:

  • FUTURE ONE TECHNOLOGY LTD (United Kingdom)
  • VELCORE TECHNOLOGY LIMITED (Hong Kong)
  • UPTECH RUNE TECHNOLOGY LLC (United States)
  • SULTAN BİLİŞİM TEKNOLOJİLERİ SANAYİ VE TİCARET LİMİTED ŞİRKETİ (Türkiye)
  • MONERA TRADING LTD (Northern Cyprus)

Compliance responsibilities may be handled by the relevant entity depending on the transaction.

3. Risk-Based Approach

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

Risk levels may include:

  • Low Risk
  • Medium Risk
  • High Risk

Risk evaluation is based on:

  • Geographic location
  • Transaction behavior
  • Payment method
  • Frequency and volume of transactions

4. Customer Identification (KYC)

We may require users to complete identity verification procedures including:

4.1 Individual Customers

  • Full name
  • Date of birth
  • Government-issued ID (passport, ID card, driver’s license)
  • Proof of address

4.2 Business Customers (if applicable)

  • Company registration documents
  • Director/shareholder information
  • Beneficial ownership details
  • Business address

We reserve the right to request additional documentation when necessary.

5. Transaction Monitoring

We actively monitor transactions for suspicious activity, including:

  • Unusual transaction patterns
  • High-value transactions
  • Rapid repeated purchases
  • Use of multiple payment methods

Automated and manual review systems are used.

6. Suspicious Activity

Transactions may be flagged or blocked if:

  • There is a suspicion of fraud or money laundering
  • Inconsistent user information is detected
  • Unusual behavior patterns are identified

We reserve the right to:

  • Freeze transactions
  • Suspend accounts
  • Request additional verification

7. Sanctions & Prohibited Countries

We comply with international sanctions and regulations.

Users from restricted or sanctioned jurisdictions may be:

  • Denied access
  • Subject to enhanced due diligence
  • Blocked from transactions

8. Record Keeping

We maintain records of:

  • Customer identification data
  • Transaction history
  • Communication logs

Records are stored securely and retained in accordance with legal requirements.

9. Data Protection

All collected data is processed in accordance with our Privacy Policy.

We implement:

  • Secure data storage
  • Encryption measures
  • Restricted access controls

10. Reporting Obligations

Where required by law, we may report suspicious activities to:

  • Financial regulatory authorities
  • Law enforcement agencies

11. User Responsibilities

Users agree to:

  • Provide accurate and truthful information
  • Cooperate with verification processes
  • Not engage in illegal or fraudulent activities

Failure to comply may result in account termination.

12. Compliance Measures

We maintain internal procedures including:

  • Risk assessment frameworks
  • Staff awareness and compliance controls
  • Ongoing monitoring and system updates

13. Policy Updates

This policy may be updated at any time to reflect:

  • Regulatory changes
  • Operational improvements

Continued use of the platform constitutes acceptance of updates.

14. Contact

For compliance-related inquiries:

Email: destek@epinsultan.com