AML & KYC policy

Summary of our anti-money-laundering (AML) and know-your-customer posture. Pre-launch draft; the full policy is maintained internally and finalised with counsel.

Know-your-business (KYB)

Every business that applies is subject to KYB review before activation. We collect corporate identity documents and information on directors, ultimate beneficial owners, and authorised representatives. Applications are reviewed by a person; there is no automatic approval.

Sanctions screening

Cardholders are screened against consolidated sanctions lists — including OFAC, UN, EU, and MAS — before any card is issued. A positive match blocks issuance and triggers review. Screening is performed before personal data is forwarded to the card issuer, and active cardholders are re-screened periodically.

Issuer of record

Cards are issued by Sunrate Pte. Ltd. (UEN 201934985D), a Major Payment Institution licensed by the Monetary Authority of Singapore and a Mastercard principal member. AdvoPay, operated by ADVO-CONSULT GmbH, acts as a technology and distribution layer and supports the issuer’s compliance requirements.

Record keeping

We retain KYB, transaction, and screening records in line with applicable regulatory requirements. AML record-retention obligations may override deletion requests for the records concerned.

Reporting

We cooperate with lawful requests from regulators and law-enforcement authorities and escalate suspicious activity in accordance with applicable law.

Last updated: pre-launch draft.