Anti-Money Laundering & Counter-Terrorist Financing Policy
Entity: Wellin Capital Co., Ltd
Product: Cashai platform
Effective Date: 1 January 2025
Version: 1.0
Wellin Capital (“the Company”) is committed to preventing the misuse of the Cashai platform for:
• Money Laundering
• Terrorist Financing
• Fraud, corruption and proceeds of crime
This policy defines the minimum AML/CFT standards applicable to all Cashai operations globally.
This policy is established in accordance with:
• FATF 40 Recommendations
• Bank of Thailand AML/CFT Regulations
• United Nations Sanctions Regime
• OFAC SDN & Sectoral Lists
• EU AMLD 5 & 6
• MAS PS-N01 AML Guidelines
Position Responsibility Board of Directors Ultimate AML accountability AML Compliance Officer (AMLCO) Daily AML control & reporting Risk Committee Risk framework approval Operations Team KYC, monitoring, escalation Internal Audit Annual AML assessment
Cashai applies a risk scoring model across:
• Customer type
• Geography
• Transaction behavior
• Loan pattern frequency
• Device & IP intelligence
5. Customer Due Diligence (CDD)
• Full legal name
• National ID / Passport
• Facial recognition & liveness check
• Proof of address
• Source of income declaration
All customers must pass identity verification before any loan disbursement.
6. Enhanced Due Diligence (EDD)
EDD is mandatory for:
• Politically Exposed Persons (PEPs)
• High-risk jurisdictions
• Complex repayment structures
• Repeated early settlement behavior
EDD includes:
• Additional document verification
• Source of wealth analysis
• Senior management approval
7. Sanctions & Watchlist Screening
Cashai screens all customers against:
• UN Sanctions
• OFAC SDN
• EU Consolidated Lists
• Domestic AML Blacklists
Screening is performed:
• At onboarding
• Prior to every loan payout
• Daily batch re-screening
Automated monitoring flags:
Risk Indicator Example Structuring Artificial splitting of repayments Velocity Excessive loan cycling Geography anomaly IP mismatch with KYC Financial inconsistency Repayment beyond declared income
9. Suspicious Transaction Reporting
Suspicious activity must be escalated to AMLCO within 24 hours.
The AMLCO files STRs to the competent authority within statutory timelines.
All AML records are retained for 10 years including:
• KYC files
• Transaction logs
• STR filings
• Audit reports
• Mandatory AML training annually
• Quarterly high-risk scenario drills
• Induction AML training for all new hires
• Annual internal AML audit
• Biennial external compliance review
Any breach of this policy may result in:
• Immediate suspension
• Termination
• Referral to law enforcement