1. Overview
QOR LTD, trading as Cashmama, is committed to preventing its platform from being used for money laundering, terrorist financing, or any other financial crime. This Anti-Money Laundering (AML) Policy sets out our approach to identifying, assessing, and mitigating such risks.
This policy applies to all users of the Cashmama platform and all transactions processed through our Services.
2. Legal Framework
Cashmama complies with applicable anti-money laundering and counter-terrorism financing (CTF) laws and regulations in the jurisdictions in which we operate. Our AML programme is designed to meet the requirements of:
- The Financial Action Task Force (FATF) recommendations
- Applicable national AML and CTF legislation
- Regulatory guidance issued by our licensing and oversight bodies
This policy is reviewed and updated regularly to reflect regulatory developments.
3. Know Your Customer (KYC)
All users must complete identity verification before accessing full platform features. Our KYC process includes:
**Identity verification**: Collection and verification of government-issued photo ID (national ID card, passport, or driver's licence).
**Liveness check**: A selfie or biometric check to confirm the user is the person named in the ID document.
**Address verification**: In some cases, proof of address may be required.
**Enhanced due diligence (EDD)**: Applied to higher-risk users, politically exposed persons (PEPs), and transactions above certain thresholds.
Users who do not complete KYC will have limited access to the platform and lower transaction limits.
4. Transaction Monitoring
Cashmama operates a real-time transaction monitoring system that analyses all transactions for suspicious patterns, including:
- Unusual transaction volumes or frequencies
- Transactions inconsistent with a user's profile or history
- Transfers to or from high-risk jurisdictions
- Structuring (breaking large transactions into smaller ones to evade detection)
- Rapid fund movements with no apparent economic purpose
Flagged transactions are reviewed by our compliance team and may be subject to additional verification, delay, or rejection.
5. Suspicious Activity Reporting
Where we identify or suspect money laundering or terrorist financing, we are legally obligated to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant financial intelligence unit without notifying the user ("tipping off").
Users must not attempt to circumvent our monitoring systems. Doing so is a criminal offence and will result in immediate account suspension.
6. Sanctions Compliance
Cashmama screens all users and transactions against applicable sanctions lists, including those maintained by:
- The United Nations Security Council
- The Office of Foreign Assets Control (OFAC)
- The European Union
- HM Treasury (UK)
- Other relevant national and international bodies
Transactions involving sanctioned individuals, entities, or jurisdictions are blocked and reported to relevant authorities as required by law.
7. Record Keeping
Cashmama retains records of all transactions, KYC documentation, and AML-related activities for a minimum of five (5) years after the date of the transaction or account closure, as required by applicable regulations.
These records are maintained securely and made available to regulatory authorities upon lawful request.
8. Staff Training
All Cashmama employees and contractors who interact with financial transactions or customer data receive regular AML and CTF training. This includes training on:
- Recognising signs of money laundering and suspicious activity
- Reporting obligations and procedures
- Sanctions compliance
- Customer due diligence requirements
9. Prohibited Use
The following activities are strictly prohibited on the Cashmama platform:
- Money laundering or attempting to disguise the proceeds of crime
- Terrorist financing or supporting sanctioned persons or organisations
- Tax evasion
- Structuring transactions to avoid reporting thresholds
- Using the platform to transact on behalf of an undisclosed third party
Violations will result in immediate account suspension, funds being frozen, and mandatory reporting to relevant authorities.
10. Contact
For questions about our AML policy or to report suspicious activity, contact our Compliance team:
**QOR LTD (trading as Cashmama)**
Email: admin@cashmama.org
If you believe your account has been involved in fraudulent activity, contact admin@cashmama.org immediately.