KYC/AML External Policy – Masspool Pte. Ltd.
Introduction
This External Policy (KYC/AML Policy) of Masspool Pte. Ltd., a private company limited by shares incorporated in Singapore (the “Company”), is established to prevent and mitigate possible risks of the Company being involved in illegal or illicit activities, including money laundering, terrorism financing, or fraud, and to ensure compliance with applicable Singaporean and international regulations.
All terms and definitions used in this Policy but not specifically defined herein shall have the meaning assigned in the Terms of Service of the Platform or, where not defined there, shall be interpreted in accordance with Singapore law and internationally accepted practice.
Any reference to “you”, “your”, etc. refers to the User of the Services.
Definitions
- Account – User’s personal account on the Platform accessible with login-password credentials.
- Company / we – Masspool Pte. Ltd., incorporated under the laws of Singapore, UEN [insert UEN], registered office at [insert address].
- Digital Assets – Cryptocurrencies or other blockchain-based digital assets.
- Platform – Website https://masspool.io and all related services.
- User – Individual or legal entity registered on the Platform and using Services.
- KYC/AML verification – Procedures to confirm User identity, beneficial ownership, and source of funds to ensure compliance with AML/CFT obligations.
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Purposes and Legal Basis
1.1. The Company is committed to providing Users a lawful and secure environment.
1.2. We recognize that money laundering and terrorism financing undermine financial integrity and can expose Users and the Company to significant legal, financial, and reputational risks.
1.3. The Company complies with requirements of:
- Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA), Cap. 65A
- Terrorism (Suppression of Financing) Act (TSFA), Cap. 325
- Monetary Authority of Singapore (MAS) Notice PSN02 / PSN04 (AML/CFT requirements for payment and DPT service providers)
- United Nations Act (Cap. 339) and applicable international sanctions.
1.4. The Company applies a risk-based approach (RBA) to AML/CFT compliance in line with Financial Action Task Force (FATF) recommendations.
Scope
This Policy applies to all Users of the Platform. Users must also comply with AML/CFT laws in their jurisdictions. The Company may decline to establish or may terminate relationships with Users from high-risk jurisdictions.
3. Principles of User Due Diligence
3.1. The Company applies KYC procedures at onboarding, during the relationship, and when suspicious activities are detected.
3.2. Due diligence measures include:
- Verifying User identity using reliable documents/data.
- Establishing purpose and nature of the business relationship.
- Monitoring for unusual or suspicious transactions.
3.3. Enhanced Due Diligence (EDD) applies where Users present higher risks (e.g., PEPs, high-risk jurisdictions).
4. KYC/AML Verification
We process personal data under the following legal grounds:
- Verification normally completed within 3–5 business days upon receipt of required documents.
- Additional documents may be requested in cases of high-risk profiles or suspicious activity.
- Forged or misleading information leads to termination and possible reporting to authorities.
5. Risk Assessment
The Company maintains a User Risk Profile based on:
- Geographic risks – high-risk or sanctioned countries.
- User risks – PEP status, unclear source of funds, use of anonymity tools.
- Transaction risks – large or unusual patterns without clear economic purpose.
- Channel risks – anonymity-enhancing channels or third-party funding.
Prohibited jurisdictions
Masspool prohibits services for Users from or associated with:
- DPRK, Iran, Sudan, Myanmar
- Countries/territories under UN or MAS sanctions
- Transaction risks – large or unusual patterns without clear economic purpose.
- Unrecognized or disputed territories (e.g., Crimea, Donetsk/Luhansk).
6. Continuous Monitoring
- Transactions are monitored to ensure consistency with User profiles.
- KYC data is retained for at least 5 years after account closure or last transaction, or longer if required by law.
- Data may be disclosed to competent Singaporean or international authorities upon lawful request.
- Confidentiality of User information is strictly maintained.
7. Termination Obligations
The Company will refuse or terminate relationships if:
- User fails to provide requested KYC/AML documents.
- Information is false, forged, or misleading.
- User attempts to circumvent AML procedures.
- There is reasonable suspicion of involvement in money laundering, terrorist financing, or other criminal activities.
8. Sanctions Compliance
The Company applies UN, MAS, and other applicable international sanctions lists. Any User or transaction linked to sanctioned entities will be rejected and reported to relevant authorities.
9. Policy Amendments
This Policy may be updated to reflect regulatory or operational changes. The effective date of the update is the date of its publication on the Platform.
10. Contact
For any questions related to this Policy, Users may contact:
Compliance Department – Masspool Pte. Ltd.
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