AML/CTF Policy

Voicespin LTD 513983676 (“Voicespin”) is committed to conducting its business in accordance with all applicable laws and regulations, enhancing its reputation in the market. This policy records Voicespin’s approach to identifying, mitigating, and managing the risk that Voicespin products and services might be involved in facilitating money laundering or financing terrorism.

Description of money laundering and terrorism financing

Voicespin defines money laundering (“ML”) as an activity designed to conceal or disguise the true origin of criminally derived proceeds to make them appear to have been sourced from legitimate sources.

Terrorist Financing (“TF”) is considered to provide financial support to terrorism or terrorist organizations to enable them to carry out acts of terrorism.

Objectives of Voicespin's AML/CTF policy

Voicespin has established an AML/CTF policy that sets the core principles for managing ML/TF risk. The policy is global and outlines group-wide standards to meet regulatory and ethical obligations in the economies in which Voicespin does business. This contributes to the stability, integrity, and strength of the global financial system and protects Voicespin from reputational damage and regulatory action.

The core principles

Voicespin has adopted the following core principles:

Voicespin opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.

Voicespin will endeavor to provide its products and services only for legitimate purposes to customers whose identities Voicespin has been able to ascertain reasonably.

Voicespin will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by Voicespin’s AML/CTF Program. • Voicespin employees are required to attend AML/CTF training to understand their obligations under the relevant laws, rules, and regulations.

Voicespin will monitor its customers, their transactions, and their employees, consistent with the level of money laundering and terrorist financing risk they represent.

Voicespin will manage new and revised changes to Voicespin’s products, business processes, and systems to ensure that money laundering and terrorist financing risks are identified and managed.

Know Your Customer ("KYC")

Voicespin endeavors to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity and bona fides of customers will also be complied with.

These will include:

Customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk Voicespin and require a higher level of due diligence; • Procedures to establish if customers are known or suspected money launderers, terrorists, or otherwise engaged in criminal activity (e.g., reviewing customers against government/United Nations/regulators’ lists of proscribed persons);

Enhanced Due Diligence is undertaken where a transaction or a counterparty results in a heightened level of financial crime or reputational risk;

A risk-based periodic review of existing customer records to maintain currency and completeness; • Ongoing monitoring of transactions conducted by customers using a risk-based approach; • Procedures prohibiting accounts/relationships, including payment processing, with shell banks; • A clear statement on what records must be kept on customer identification and individual transactions and their retention period;

Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.

Suspicious Activity

Voicespin staff is trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with customers and customer-related information.
Voicespin has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.

Voicespin AML/CTF training program

Voicespin has a robust AML/CTF Training Program to educate employees in implementing and maintaining Voicespin’s AML/CTF Program. Relevant employees undergo initial AML/CTF training when they join Voicespin. In addition, there are ongoing training requirements for all relevant employees.