Entity: VGTopup | Operated by: JOYTOPUP LIMITED |
Address: RM 102, 1/F, THE CLOUD, 111 TUNG CHAU STREET, TAI KOK TSUI, HONG KONG
1. Purpose
This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy sets out VGTopup's standards,
controls, and procedures designed to prevent, detect, and report money laundering, terrorism financing,
proliferation financing, and other financial crimes associated with services offered on the VGTopup platform.
2. Scope
This Policy applies to all products, services, and business lines of VGTopup, and to all employees, officers,
directors, contractors, agents, and affiliated third parties. It covers all users and customers (retail and
institutional) interacting with the platform, regardless of location, subject to applicable laws.
3. Key Definitions
Money Laundering (ML): The process of concealing the illicit origin of proceeds of crime.
Terrorist Financing (TF): The provision or collection of funds to support terrorist acts or
organizations.
Proliferation Financing (PF): Financing the proliferation of weapons of mass destruction.
Customer Due Diligence (CDD): Identity verification and risk assessment measures applied to
customers.
Enhanced Due Diligence (EDD): Additional due diligence for higher-risk customers, products, or
geographies.
Politically Exposed Person (PEP): A person entrusted with prominent public functions, including
family members and close associates.
Sanctions: Restrictive measures issued by competent authorities (e.g., UN, OFAC, EU, UK HMT,
and local lists).
4. Regulatory Framework
VGTopup commits to complying with all applicable AML/CTF laws and regulations of Hong Kong, relevant
extra-territorial requirements, and internationally recognized standards including the Financial Action Task Force
(FATF) Recommendations. Where conflicts arise between this Policy and local laws, the stricter standard applies to
the extent permitted by law.
5. Risk-Based Approach
VGTopup applies a risk-based approach (RBA) to identify and mitigate ML/TF/PF risks.
5.1 Risk Assessment
Assess inherent and residual risk across customers, products/services, delivery channels, and geographies.
Update assessments at least annually or upon material changes (e.g., new products or markets).
5.2 Risk Mitigation
Implement controls commensurate with risk (CDD tiers, limits, monitoring rules, and reviews).
Document rationales for risk acceptance, mitigation, or avoidance.
6. Governance & Responsibilities
Board/Management: Approves this Policy, sets risk appetite, ensures resources and oversight.
AML Compliance Officer (MLRO): Oversees AML program, reports to the Board, manages
investigations and regulatory liaison.
All Personnel: Must follow this Policy, complete training, and escalate concerns immediately.
7. Customer Due Diligence (CDD)
7.1 When CDD Is Required
On onboarding and before providing services.
When suspicion of ML/TF/PF arises.
Upon material changes or doubts about previously obtained data.
7.2 Identification & Verification (KYC)
Individuals: Full name, date of birth, nationality, residential address, selfie/biometric where
lawful, and government-issued ID.
Validate information using reliable, independent sources and, where appropriate, digital identity solutions.
7.3 Purpose & Intended Nature
Collect information about expected activity, source of funds, and, for higher risk, source of wealth.
7.4 CDD Tiers
Simplified Due Diligence (SDD): Allowed only where demonstrably low risk and legally permitted.
Standard CDD: Default level for most customers.
Enhanced Due Diligence (EDD): Required for high-risk customers, PEPs, high-risk geographies,
complex ownership structures, or adverse media.
7.5 Failure to Complete CDD
VGTopup will not establish or maintain a relationship, and will consider filing a report where warranted.
8. Enhanced Due Diligence (EDD)
Obtain senior management approval to onboard or maintain high-risk customers.
Corroborate source of funds and, where applicable, source of wealth.
Apply stricter limits, increased monitoring frequency, and periodic reviews.
For PEPs: assess role, influence, and proximity; perform adverse media and sanctions screening with ongoing
monitoring.
9. Ongoing Monitoring & Screening
Monitor activity against risk profiles and expected behavior to detect anomalies.
Screen customers and transactions against up-to-date sanctions, watchlists, and PEP lists at onboarding and on a
continuous basis.
Review and update customer information periodically, risk-based.
Investigate alerts promptly; document decisions and rationales.
10. Transaction Controls
Set risk-based limits on deposits, withdrawals, purchases, and redemptions.
Restrict or prohibit transactions involving high-risk jurisdictions or sanctioned persons/entities.
Apply blockchain analytics and address-risk screening for virtual asset flows where applicable.
Implement velocity checks, device/IP risk controls, and multi-factor authentication.
Hold, pause, or decline transactions pending review where red flags are identified.
11. Suspicious Activity Reporting
Employees must escalate unusual or suspicious activity to the AML Compliance Officer (MLRO) immediately.
Where required, the MLRO will file internal reports and external reports to the competent Financial Intelligence
Unit (FIU) in Hong Kong without tipping off the customer.
All investigations and filings are documented and retained confidentially.
12. Record Keeping
Retain CDD/KYC records, transactions, screening logs, monitoring alerts, investigations, and training records
for the periods required by applicable law.
Ensure records are retrievable promptly for regulatory requests and audits.
13. Training & Awareness
Provide role-based AML/CTF training at onboarding and at least annually.
Address: RM 102, 1/F, THE CLOUD, 111 TUNG CHAU STREET, TAI KOK TSUI, HONG KONG
22. Disclaimer
This Policy provides a general overview of VGTopup's AML/CTF program. It does not create any private right of
action and may be supplemented by procedures not publicly disclosed. Nothing in this document constitutes legal
advice.