EMerchants is committed to complying with the letter and the spirit of the AML/CTF legislation.  We have developed an AML/CTF policy which clearly sets out our approach to the identification, mitigation and management of the risks that we can reasonably anticipate.  In approving, implementing and formally adopting this Policy, our objectives are to:

• Establish the core principles that guide the way we identify, manage and mitigate the risk of money laundering or terrorist financing occurring through our company;
• Ensure that we meet our legal and regulatory obligations, and that our staff are trained to comply with these requirements; and
• Oppose the crimes of money laundering and terrorism financing to protect our company, our people and our shareholders from the reputational damage, regulatory intervention and potential financial penalties attached to non-compliance with legislative AML/CTF obligations.

1. Core AML/CTF Principles

EMerchants approach to AML/CTF issues is centred on the following core principles:

• We oppose the crimes of money laundering and terrorist financing and do not tolerate the use of our products and services for either of these purposes;
• We report any activity that we detect which falls within the scope of the AML/CTF Act to the AUSTRAC CEO;
• We are committed to complying with the letter and the spirit of all the AML/CTF laws of the countries where we have permanent places of business;
• We will seek to provide our products and services only for legitimate purposes to customers whose identities we have been able to reasonably ascertain;
• We will seek to avoid relationships with those that we reasonably assess as posing an unacceptable risk of money laundering or terrorist financing, and we will assess the viability of maintaining ongoing relationships with customers that fit this criteria;
• We will not tolerate behaviours that compromise EMerchants compliance with AML/CTF legislation;
• Our people will be assigned clear AML/CTF responsibilities, relevant to their respective roles and areas, as appropriate;
• Our people will receive the AML/CTF training they need to understand and fulfil their obligations under the AML/CTF legislation and our AML/CTF Program;
• We will monitor, measure and report compliance with our AML/CTF Program, and take corrective actions as necessary; and
• We will manage changes to our products, business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.

2. Administrative Information

• Legal name: EMerchants Ltd
• Principal place of business: 3/54 Vernon Tce Teneriffe QLD 4005
• Place of incorporation: Brisbane, Australia
• Legal status: Public Limited Company
• Major shareholders: Private
• Regulators: Australian Securities and Investment Commission (ASIC), Australian Transaction Reports and Analysis Centre (AUSTRAC)
• Australian Financial Services Licence: 259689
• External auditors: BDO Kendalls
• AML contact: Andrew Betts
• Address: 3/54 Vernon Tce Teneriffe QLD 4005
• Phone number: 61 7 3607 0100
• Fax number: 61 7 3607 0111
• Email address: abetts@emerchants.com.au

3. Senior Management

Senior Management

• John Battley - Chief Operating Officer
• Anthony Ferguson - Chief Information Officer
• Juanita Oversby - Financial Manager
• Mark Hogben -Software Deveplopment Manager
• Craig Waterhouse -IT Infrastructure Manager
• Donna Ferguson - Business Development Manager
• Andrew Betts - Compliance Manager
• Ty Schrader - Treasury Manager
• Justin McCloughan - Customer Service Manager

4. Anti-Money Laundering and Counter-Terrorism Financing Measures in EMerchants

EMerchants is subject to, and complies with, Australian law. Australian laws applicable to EMerchants:

• Financial Transaction Reports Act 1988 and associated regulations
• Proceeds of Crime Act 2002 and associated regulations
• Criminal Code Act 1995 and associated regulations

The principal piece of legislation is the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). Under the AML/CTF Act. AUSTRAC, the regulatory authority charged with oversight of the legislation, has made Rules relating to AML/CTF obligations. EMerchants has implemented the requirements of this Act within the specified timeframes. EMerchants has adopted internal policies, procedures and controls to ensure that it complies with existing legislation.

1. Customer due diligence / Know Your Customer:
   EMerchants has policies and procedures in place to comply with the obligation to identify customers as required by legislation. The legislated risk based approach requires EMerchants to perform tailored due diligence on customers based on an assessment of the associated Money Laundering/Terrorism Financing (ML/TF) risk. The recently enacted AML/CTF Act 2006 also requires Ongoing and Enhanced Customer Due Diligence for certain higher risk customers. Controls and assurance processes are being enhanced within timeframes specified in the AML/CTF Act 2006. These enhancements include monitoring of customer transactions based on an assessment of the associated ML/TF risk.
   
2. Record retention:
   Records relating to customer identification are maintained and kept for seven (7) years in Australia after the termination of services offered by EMerchants.
   
3. Monitoring of suspicious activities or transactions:
   Monitoring is carried out through a risk-based approach. EMerchants staff receive periodic training and reminders of the requirements to report suspicious transactions and how to identify them.
   
4. Reports of suspicious transactions:
   EMerchants is required to report any suspicious customer activities or transactions to the regulatory authority, AUSTRAC. Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements.
   
5. Reports of significant account and non-account based cash transactions:
   EMerchants is required to report these activities to the regulatory authority, AUSTRAC. Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements.
6. Employee training program:
   Training is provided to business units that offer products and services that are subject to the legislative requirements. EMerchants staff impacted by the Act receive periodic training and reminders on the detection and reporting process for suspicious activities, new customer identification procedures, and record keeping. Communication of changes to AML/CTF legislation or any emerging risks are communicated to the relevant staff.
   
7. Agents of EMerchants:
   are required to carry out their duties in accordance with agreements entered into with them and includes where applicable any customer identification and know your customer requirements. In complying with the recently enacted AML/CTF Act 2006, controls and assurance processes including training are being enhanced to within timeframes specified in the AML/CTF Act 2006.  
   
8. Independent audit and compliance review function:
   EMerchants auditors and internal audit conduct audits and compliance testing of all EMerchants policies and operational procedures including those applicable to AML. The audit and compliance programs are approved by senior management.
   
9. Correspondent banks:
   EMerchants does not have any Correspondent Banking relationships.
   
10. Shell banks:
    EMerchants does not conduct business with shell banks.
    
11. PEPs:
    A risk based approach considers PEPs as a ML/TF risk.
12. AML Officer:
    The contact for AML related matters has been provided above. In complying with the recently enacted AML/CTF Act 2006, EMerchants has designated a person as the 'AML/CTF Compliance Officer' at the appropriate management level.