AML - eSimsData

Policy on the Prevention of Money Laundering, Terrorist Financing, and Know Your Customer (KYC)

Introduction

esimsdata.com (hereinafter referred to as “the Company”) is operated by Siamocean OÜ, a legal entity incorporated under the laws of the Republic of Estonia. The Company operates a global online platform for the sale of eSIMs, mobile balance top-ups, and gift cards.

This Policy is designed to minimize the risk of the Company being used for money laundering, terrorist financing, or other illegal activities, in accordance with international standards and applicable legislation.

Our Commitment

The Company implements internal procedures and mechanisms to prevent and detect:

Money laundering
Terrorist financing
Drug and human trafficking
Proliferation of weapons of mass destruction
Corruption and bribery
Any other suspicious or unlawful activity

Definitions

Money Laundering is defined as the process of concealing the origins of money obtained through criminal activity by transferring it through legitimate businesses or complex financial transactions.

Terrorist Financing is the act of providing or collecting funds, directly or indirectly, with the intention that they will be used to support terrorist activities.

Legal and Regulatory Framework

We are guided by the following regulations and international standards:

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Joint Money Laundering Steering Group (JMLSG) Guidelines (UK)
Recommendations of the Financial Action Task Force (FATF)
5th Anti-Money Laundering Directive (EU) 2018/843
Anti-Terrorism Acts 2000 and 2001
Counter-Terrorism Act 2008
Financial Conduct Authority (FCA) Handbook (UK)

Risk-Based Approach

We apply a risk-based approach to evaluate and mitigate risks associated with money laundering and terrorist financing. This allows us to tailor our controls to the level of risk presented by each customer and transaction.

Internal Measures

To implement this Policy, we have introduced the following internal measures:

Establishment of a comprehensive Know Your Customer (KYC) procedure
Risk-based user profiling and enhanced due diligence when necessary
Timely response to inquiries from law enforcement and regulatory authorities
Monitoring and reporting of suspicious activities
Use of anti-fraud and identity verification tools
Ongoing AML/KYC training for employees

User Verification Procedure

Our verification process includes the following levels:

Identity Verification – The user must submit personal information and a clear digital copy of their international passport or national ID.
Selfie Verification – The user must upload a selfie holding the same identity document next to their face.
Payment Card Verification (if paying by card) – The user must complete a form with card details and upload a photo holding the card (with the middle 8 digits hidden) next to their face.

Compliance and Enforcement

We process requests from regulatory bodies, monitor account activity, and reserve the right to suspend or terminate accounts involved in suspicious or unlawful activities.

Language and Legal Priority

This AML/KYC Policy is originally written in English and may be translated into other languages for convenience. In case of any discrepancy between translations, the English version shall prevail.