AML / CFT policy

555GROUP PTE. LTD. (UEN: 202006462D) operates in line with the Monetary Authority of Singapore (MAS) and is a Standard Payment Institution (SPI) applicant under the Payment Services Act 2019 (PSA). Our framework is designed to meet the obligations in:

• MAS Notice PSN01 — Prevention of Money Laundering and Countering the Financing of Terrorism for SPIs and MPIs;
• MAS Notice PSN02 — Prevention of Money Laundering and Countering the Financing of Terrorism for Digital Payment Token services (where applicable);
• the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA) and the Terrorism (Suppression of Financing) Act (TSOFA);
• United Nations sanctions transposed into Singapore law and the Targeted Financial Sanctions regime.

Wallet balances are safeguarded in a Singapore-licensed trust account at a MAS-regulated bank, ring-fenced from operating funds.

The Board has ultimate accountability for AML/CFT effectiveness. A designated Money Laundering Reporting Officer (MLRO) and a Deputy MLRO oversee day-to-day compliance, sanctions screening, and Suspicious Transaction Report (STR) filing. Senior management approves the AML/CFT policy at least annually and on material change.

We operate a three-lines-of-defence model: business teams own controls, an independent compliance function challenges them, and internal audit reviews both at least annually.

We assess money-laundering, terrorism-financing, and proliferation- financing risk across customer types, geographies, products, channels, and transaction patterns. The enterprise-wide risk assessment is refreshed at least annually and after material change (new product, new market, regulatory update). Controls scale with risk: more friction where it is warranted, less where it is not.

We verify the identity of every wallet holder and every merchant before the account is activated. CDD includes:

• Individuals — full name, date of birth, nationality, residential address, ID number, and a government- issued document verified through Singpass Myinfo where possible and a liveness selfie matched against the document otherwise;
• Businesses — registered name, UEN, business activity, registered address, directors and authorised signatories, and identification of beneficial owners holding 25% or more (or exercising control by other means);
• Purpose and intended nature of the relationship, and ongoing monitoring against that profile.

CDD is refreshed when a trigger event occurs (significant change in ownership, transaction-pattern shift, expired ID), and on a time-driven cadence calibrated to risk. We do not establish a relationship until CDD is satisfactorily completed.

EDD applies to higher-risk relationships — politically exposed persons (PEPs) and their close associates, customers from higher-risk jurisdictions, complex ownership structures, and customers exhibiting unusual transaction profiles. EDD includes senior- management approval to onboard or continue the relationship, source- of-funds and source-of-wealth checks, and tightened ongoing monitoring.

All customers, beneficial owners, signatories, and counterparty merchants are screened at onboarding and on a continuous basis against United Nations, MAS Targeted Financial Sanctions, US OFAC, UK HM Treasury, and EU consolidated sanctions lists, plus a recognised PEP and adverse-media dataset. True-match hits are frozen pending review and reported to MAS where required by the relevant sanctions regulations.

Wallet and merchant activity is monitored in real time and on a batch basis against a tuned set of typologies — including structuring, rapid in-and-out flows, geographic anomalies, mismatch with expected profile, layering through multiple counterparties, and indicators of mule activity. Alerts route to trained compliance analysts; unresolved alerts escalate to the MLRO.

Where reasonable grounds for suspicion exist, we file a Suspicious Transaction Report with the Suspicious Transaction Reporting Office (STRO) within the timeframe required by the CDSA and TSOFA. We do not tip off the subject of a report. Where appropriate we apply a freeze on the relevant funds or accounts pending guidance from authorities.

CDD/EDD records, transaction data, screening results, alert dispositions, and STR documentation are retained for at least five years after the end of the customer relationship or the date of the transaction, whichever is later, in line with the PSA and MAS PSN01. Records are stored securely with access logging and are produced to MAS or law enforcement on lawful request.

All staff complete AML/CFT and sanctions training at induction and at least annually thereafter, with role-specific deep-dives for customer-onboarding, payments-operations, engineering, and senior management. Training participation is tracked and reported to senior management.

The framework is independently reviewed at least annually and after material change. Findings are tracked to closure with senior- management oversight. Material findings and remediation status are reported to MAS where required.

Staff and external parties can raise concerns confidentially to [email protected]. Reports are handled by the audit committee independently of line management. We do not tolerate retaliation against good-faith reporters.

Money Laundering Reporting Officer (MLRO): [email protected]
Regulator enquiries: [email protected]
Mailing address: 555GROUP PTE. LTD., 68 Kaki Bukit Avenue 6, #01-09, Singapore 417896.