1. Purpose and Scope
This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy sets out the principles, procedures, and controls that NML — New Media License PTE LTD ("NML", "we", "us", or "our") has established to prevent the use of our services for money laundering, terrorist financing, and other financial crimes.
This policy applies to all directors, officers, employees, contractors, and agents of NML, as well as to all business relationships and transactions conducted through our services. It covers our operations across all jurisdictions in which we operate, including Singapore and the European Union.
NML is firmly committed to conducting business with integrity and in full compliance with all applicable anti-money laundering laws and regulations. We maintain a zero-tolerance approach to money laundering and terrorist financing and expect the same standard from our clients, partners, and service providers.
2. Regulatory Framework
NML's AML and KYC procedures are designed to comply with the following regulatory frameworks:
Singapore
- Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
- Terrorism (Suppression of Financing) Act (TSOFA)
- Monetary Authority of Singapore (MAS) Notices and Guidelines on Prevention of Money Laundering and Countering the Financing of Terrorism
- Payment Services Act 2019 and associated regulations
European Union
- Directive (EU) 2015/849 — Fourth Anti-Money Laundering Directive (4AMLD)
- Directive (EU) 2018/843 — Fifth Anti-Money Laundering Directive (5AMLD)
- Regulation (EU) 2024/1624 — Anti-Money Laundering Regulation (AMLR)
- Applicable national implementing legislation in EU member states where NML operates
International Standards
- Financial Action Task Force (FATF) Recommendations
- Wolfsberg Group Principles
- United Nations Security Council sanctions and resolutions
NML monitors regulatory developments across all jurisdictions in which it operates and updates its policies and procedures accordingly to ensure ongoing compliance.
3. Customer Due Diligence (CDD) and KYC Procedures
NML conducts Customer Due Diligence on all prospective and existing clients before establishing a business relationship or conducting significant transactions. Our CDD procedures are designed to verify the identity of our clients, understand the nature and purpose of the business relationship, and assess the risk of money laundering or terrorist financing.
Identification and Verification
For all new clients, we collect and verify the following information:
- Individuals: Full legal name, date of birth, nationality, residential address, and a government-issued identification document (passport, national identity card, or equivalent).
- Legal Entities: Full legal name, registered address, registration number, date and country of incorporation, business activity description, and certificate of incorporation or equivalent registration document.
- Beneficial Ownership: Identity of all individuals who ultimately own or control more than 25% of the entity, or who otherwise exercise significant control over the entity, in accordance with applicable regulations.
- Authorised Representatives: Identity and authorisation documents of individuals acting on behalf of the client.
Risk Assessment
Each client relationship is assessed for money laundering and terrorist financing risk based on factors including:
- The nature of the client's business and industry
- The geographic location of the client and its operations
- The products and services requested
- The expected volume and nature of transactions
- Whether the client or any beneficial owner is a Politically Exposed Person (PEP)
- Sanctions screening results
Based on this assessment, clients are assigned a risk rating (low, medium, or high) that determines the level of due diligence and ongoing monitoring applied.
4. Enhanced Due Diligence (EDD) for High-Risk Customers
Where a client is assessed as high-risk, NML applies Enhanced Due Diligence measures in addition to standard CDD procedures. EDD is mandatory in the following circumstances:
- The client or beneficial owner is a Politically Exposed Person (PEP), or a family member or close associate of a PEP
- The client is domiciled or operates in a jurisdiction identified as high-risk by FATF, MAS, or EU authorities
- The business relationship involves complex or unusually large transactions with no apparent economic or lawful purpose
- There are adverse media findings or negative intelligence regarding the client
- The client operates in a high-risk industry sector (e.g., gambling, cryptocurrency, cash-intensive businesses)
Enhanced Due Diligence measures include, but are not limited to:
- Obtaining additional identification documents and independent verification of the source of funds and source of wealth
- Conducting adverse media screening and enhanced background checks
- Obtaining senior management approval before establishing or continuing the business relationship
- Applying more frequent and intensive ongoing monitoring of the business relationship and transactions
- Requiring additional documentation to verify the purpose and intended nature of the business relationship
5. Transaction Monitoring
NML maintains systems and procedures for the ongoing monitoring of client transactions to detect activity that is unusual, suspicious, or inconsistent with the client's known business profile and risk assessment.
Our transaction monitoring programme includes:
- Automated monitoring systems that flag transactions meeting predefined risk-based parameters and thresholds
- Manual review of flagged transactions by trained compliance personnel
- Periodic review of client accounts and transaction patterns to identify changes in risk profile
- Screening of all transactions against applicable sanctions lists, including those maintained by the United Nations, European Union, MAS, OFAC, and other relevant authorities
- Monitoring for structuring, layering, and other common money laundering typologies
Monitoring parameters and thresholds are regularly reviewed and updated to reflect current regulatory guidance, emerging risks, and industry best practices.
6. Suspicious Activity Reporting
All NML employees are required to report any knowledge or suspicion of money laundering, terrorist financing, or other financial crime to the designated Compliance Officer without delay.
Upon receiving an internal report, the Compliance Officer will:
- Evaluate the report and conduct further investigation as necessary
- Determine whether reasonable grounds exist to file a Suspicious Transaction Report (STR) with the relevant authorities
- File STRs with the Suspicious Transaction Reporting Office (STRO) in Singapore and/or the Financial Intelligence Unit (FIU) of the relevant EU member state, as applicable
- Ensure that all reporting is conducted within the timeframes prescribed by applicable regulations
NML strictly prohibits "tipping off" — informing a client or any third party that a suspicious activity report has been or may be filed. Employees who breach this prohibition may be subject to disciplinary action and criminal penalties.
All employees are protected against retaliation for making good-faith reports of suspicious activity.
7. Record Keeping
NML maintains comprehensive records of all CDD documentation, transaction records, and compliance-related activities in accordance with applicable legal requirements.
- CDD and KYC documentation, including copies of identification documents and verification records, are retained for a minimum of five (5) years from the date of termination of the business relationship, or longer if required by applicable regulations.
- Transaction records are retained for a minimum of five (5) years from the date the transaction was completed.
- Internal suspicious activity reports, STR filings, and related investigation records are retained for a minimum of five (5) years from the date of the report or filing.
- Training records, including attendance and completion records, are retained for the duration of the employee's tenure and for five (5) years thereafter.
All records are stored securely with appropriate access controls and are made available to regulatory authorities upon lawful request.
8. Employee Training
NML provides comprehensive AML and KYC training to all employees as part of our commitment to maintaining a strong compliance culture. Our training programme includes:
- Induction Training: All new employees receive AML and KYC training as part of their onboarding process, covering the fundamentals of anti-money laundering regulations, NML's policies and procedures, and their individual responsibilities.
- Annual Refresher Training: All employees receive mandatory annual training that covers regulatory updates, emerging money laundering typologies, case studies, and practical scenarios relevant to their roles.
- Role-Specific Training: Employees in client-facing, compliance, and risk management roles receive additional specialised training tailored to their specific responsibilities and the risks associated with their functions.
- Ad Hoc Training: Additional training is provided when significant regulatory changes occur, new products or services are introduced, or specific compliance risks are identified.
Training effectiveness is assessed through testing and evaluation, and completion is documented and monitored by the Compliance team.
9. Policy Review
This AML and KYC Policy is reviewed and updated at least annually by the Compliance Officer, in consultation with senior management, to ensure its continued effectiveness and compliance with applicable laws and regulations. Reviews are also triggered by:
- Significant changes in applicable anti-money laundering laws or regulations
- Changes in our business operations, products, or services that may affect our risk profile
- Findings from internal or external audits, regulatory examinations, or compliance reviews
- Emerging money laundering or terrorist financing risks and typologies
All material updates to this policy are communicated to employees and relevant stakeholders in a timely manner.
10. Contact
For questions, concerns, or inquiries regarding this AML and KYC Policy, or to report suspicious activity, please contact our Compliance team:
Compliance Officer
NML — New Media License PTE LTD
10 Anson Road #12-14, International Plaza
Singapore 079903
Email: compliance@nml.world
Phone: +65 6123 4567