AML / KYC Policy

1. Our Commitment

ANGRA HK LIMITED (“Remitum”) is licensed as a Money Service Operator (MSO) in Hong Kong under AMLO (Cap. 615), MSO Licence No. 16-10-01954, regulated by the C&ED. Remitum is fully committed to preventing money laundering, terrorist financing, and financial crime in compliance with: AMLO and C&ED AML/CFT Guideline; FATF Forty Recommendations; applicable sanctions laws; and AML/CFT requirements of partner jurisdictions, including NB KR regulations.

2. Customer Due Diligence (CDD)

CDD is applied at commencement of business relationship; before any transaction; on ML/TF suspicion; and on doubt about prior identification data.

Standard CDD requires identifying and verifying the identity of the customer, beneficial owner, and authorised representative, plus obtaining information on the purpose of the relationship.

Corporate customers must provide: certificate of incorporation; constitutional documents; director register; UBO declaration with ID; applicable licence; board resolution or power of attorney.

3. Enhanced Due Diligence (EDD)

EDD applies to PEPs and their associates, customers from FATF high-risk jurisdictions, complex or unusually large transactions, and customers with adverse media or prior enforcement actions. EDD includes source of funds/wealth documentation, enhanced monitoring, and senior management approval.

4. Sanctions Compliance

All customers and counterparties are screened against: OFAC SDN, UN Security Council, EU Consolidated, HM Treasury, and other applicable sanctions lists, at onboarding and on an ongoing basis.

5. Infrastructure Partner - Kyrgyzstan

Certain payment processing services are provided through ClickPay, Limited Liability Company, a licensed payment organisation regulated by the National Bank Kyrgyz Republic under Licence No.3054031024, which maintains its own AML/CFT programme under Kyrgyz law. Responsibility allocation is governed by the written service agreement between the parties.

6. Suspicious Transaction Reporting

Remitum files Suspicious Transaction Reports (STRs) with the JFIU where ML/TF is known or suspected. No tipping-off of subjects of STRs.

7. Record Keeping and Training

CDD documentation and transaction records are retained for a minimum of 6 years per AMLO Schedule 2. All relevant staff undergo annual AML/CFT training.

8. Contact

Compliance: welcome@angrapay.com