Anti-Money Laundering (AML) and Anti-Fraud Policy

Effective Date: 2025-05-25
Version: 1.0
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1. Purpose
This Anti-Money Laundering (AML) and Anti-Fraud Policy outlines the measures adopted by Green Mars Services Ltd to prevent, detect, and report money laundering, terrorist financing, and fraudulent activities. We are committed to maintaining a secure and transparent ecosystem through proactive compliance and risk management, including full Know Your Customer (KYC) and Know Your Business (KYB) procedures.
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2. Scope
This policy applies to all employees, contractors, and technology partners of Green Mars Services Ltd who are involved in client onboarding, transaction handling, compliance checks, technical integration, or fraud detection.
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3. Company Role
Green Mars Services Ltd is a technical payment gateway that also performs direct KYC/KYB on clients. We do not hold client funds but provide:
• API-based transaction processing and payment routing;
• Client identity verification and risk scoring;
• Compliance and fraud detection tools;
• Integration with regulated financial institutions (PSPs, EMIs, acquiring banks).
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4. Regulatory Framework
Although Green Mars Services Ltd as a payment gateway aligns our practices with:
• FATF Recommendations;
• EU AML Directives and national transpositions;
• Local AML laws in our operating jurisdiction(s);
• Sanctions and PEP screening obligations.
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5. AML & KYC Measures

5.1. Client Due Diligence (CDD)
• Individual and business client verification using reliable, independent sources;
• UBO checks, PEP screening, and adverse media reviews;
• Ongoing due diligence based on client risk profiles.

5.2. Enhanced Due Diligence (EDD)
• Applied to clients from high-risk jurisdictions, involving large transaction volumes, or having complex ownership structures;
• Manual review and escalation prior to approval.

5.3. Ongoing Monitoring
• Regular reviews of client activity patterns and transaction behavior;
• Triggers for reassessment of risk level;
• Re-verification of client documents when necessary.

5.4. Suspicious Activity Reporting (SAR)
• Internal reporting;
• Case-by-case evaluation for potential reporting to the national Financial Intelligence Unit (FIU);
• Records of all reports retained for audit purposes.
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6. Anti-Fraud Monitoring
Green Mars Services Ltd implements dedicated anti-fraud monitoring tools and protocols, including:
• Behavioral Analysis: Real-time profiling of users to detect anomalies such as velocity attacks, repeated failed attempts, and mismatched IP/device/location combinations;
• Rule-Based Detection: Automated alerts on high-risk patterns (e.g., frequent small transactions, geographic inconsistencies, newly onboarded clients attempting large volumes);
• Chargeback Pattern Review: Tracking of merchant-initiated transactions and reviewing refund/chargeback ratios;
• Blacklisting: Systematic blacklisting of fraudulent devices, emails, or identities across the platform;
• Collaboration with Partners: Joint anti-fraud investigations with regulated financial partners when threats or abuse are detected;
• Manual Review & Escalation: Dedicated staff and escalation flows for fraud case reviews.

All suspected fraud cases are logged and reviewed, with actions taken ranging from partner notification to account termination.
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7. Data Security & Recordkeeping
• Retention of all KYC records, transaction metadata, and monitoring logs for at least 5 years;
• Secure storage and restricted access to sensitive information;
• Full GDPR compliance for EU clients and partners.
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8. Employee Awareness & Training
• Annual mandatory training on AML and fraud awareness for all employees;
• New hires must complete onboarding modules before gaining access to internal systems;
• Refresher training on evolving threats and typologies.
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Green Mars Services Ltd
Date: 2025-05-25