AML/KYC Policy

PHEloans is committed to preventing money laundering and terrorist financing. This policy outlines our compliance procedures and due diligence requirements.

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Last Updated: August 14, 2026 Compliance

PHEloans is fully committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations. We take our responsibility seriously in preventing financial crime and protecting the integrity of the global financial system.

1. Policy Statement

PHEloans maintains a zero-tolerance policy towards money laundering, terrorist financing, and other financial crimes. We are dedicated to:

  • Compliance - Adhering to all applicable AML/CTF laws, regulations, and international standards
  • Due Diligence - Conducting thorough customer due diligence on all clients and business partners
  • Risk Assessment - Implementing risk-based approaches to identify and mitigate money laundering risks
  • Transparency - Maintaining accurate records and reporting suspicious activities as required by law
  • Training - Providing regular AML/CTF training to all employees

2. Know Your Customer (KYC) Procedures

We implement comprehensive KYC procedures to verify the identity of our clients and understand the nature of their business.

2.1 Customer Identification Program (CIP)

Before establishing a business relationship, we collect and verify the following information:

  • Individuals - Full legal name, date of birth, nationality, government-issued ID (passport, driver's license), proof of address (utility bill, bank statement)
  • Business Entities - Legal name, registration number, registered address, business license, articles of incorporation, beneficial ownership information
  • Trusts/Foundations - Trust deed, details of trustees and beneficiaries, source of funds

2.2 Customer Due Diligence (CDD)

We conduct different levels of due diligence based on risk assessment:

  • Simplified Due Diligence (SDD) - For low-risk clients with lower transaction volumes
  • Standard Due Diligence (CDD) - For most clients, verifying identity and business purpose
  • Enhanced Due Diligence (EDD) - For high-risk clients, involving additional verification and ongoing monitoring

2.3 Beneficial Ownership

We identify and verify beneficial owners of legal entities (individuals who ultimately own or control 25% or more of the entity).

3. Transaction Monitoring

We employ robust transaction monitoring systems to detect and report suspicious activities:

  • Real-time monitoring - Continuous monitoring of all transactions
  • Threshold monitoring - Alerts for transactions exceeding defined thresholds
  • Pattern analysis - Detection of unusual patterns or deviations from normal behavior
  • Geographic monitoring - Monitoring transactions involving high-risk jurisdictions
  • High-risk indicators - Identifying red flags such as unusual transaction sizes, frequency, or sources of funds

4. Reporting Obligations

We comply with all reporting requirements under applicable laws:

  • Suspicious Activity Reports (SARs) - Filing SARs with relevant financial intelligence units for suspicious transactions
  • Large Currency Transaction Reports - Reporting transactions exceeding regulatory thresholds
  • Annual Compliance Reports - Submitting reports to regulatory authorities as required

5. Sanctions Compliance

We adhere to all international sanctions and embargoes:

  • OFAC Sanctions - Screening against the U.S. Office of Foreign Assets Control (OFAC) sanctions list
  • UN Sanctions - Compliance with United Nations Security Council sanctions
  • EU Sanctions - Adherence to European Union sanctions regimes
  • Other Sanctions - Compliance with sanctions from other jurisdictions as applicable

We conduct sanctions screening on all clients, business partners, and transactions to ensure compliance.

6. Record Keeping

We maintain complete and accurate records of all client information, transactions, and compliance activities for the period required by law (typically 5-7 years). These records are stored securely and made available to regulatory authorities upon request.

7. Employee Training

All employees receive regular training on AML/CTF policies, procedures, and regulatory requirements. Training includes:

  • Onboarding training - Mandatory AML/CTF training for new employees
  • Annual refresher training - Ongoing education on emerging risks and regulatory changes
  • Specialized training - In-depth training for employees in high-risk roles

8. Contact Us

If you have questions about our AML/KYC Policy or wish to report suspicious activity, please contact our Compliance Officer:

This AML/KYC Policy was last reviewed and updated on August 14, 2026.

This policy is confidential and intended solely for compliance purposes.