AML Policy


Last update: 05/15/2025

Anti-Money Laundering Policy

Policy Statement

ZSUITE GLOBAL INC is a legal, ethical and transparent company, and it takes the responsibility to ensure and maintain that its assets and resources are not being used for corruption, irregularities, or money laundering. The company has taken it upon itself to detect frauds, irregularities, abuse of position, and institutional gains.

Purpose

The purpose of this policy is to ensure that the company’s financial processes and procedures are according to the anti-money laundering laws.

Scope

This policy applies to every entity related to ZSUITE GLOBAL INC and its employees, directors, officers, contractors, or any third party working on behalf of the company.

The policy is for internal use, and the administration is required to convey it to every concerned person or entity. Failure to comply with the policy will result in appropriate action.

Money Laundering

Money laundering refers to those assets that are money that is acquired in exchange for money or assets gained unlawfully. It also includes money spent for terror purposes, regardless of the means it was obtained.

Under this policy, money earned by using the following means is considered money laundering, and it is prohibited;

  1. Money or assets received in exchange for criminal or unlawful acts. Money whose origin is not explicit or earned by assisting any activity in evading lawful means.
  2. Property gained after any criminal activity and its origin, location, and disposition are not transparent.
  3. Property which is promoting any unlawful activity
  4. Terrorism financing

Sanctions policy

ZSUITE GLOBAL INC Services are subject to economic sanctions programs administered in the countries where we conduct business, including but not limited to those administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to which we are prohibited from providing services or entering into relationships with certain individuals and institutions. By using the Services, you represent that your actions are not in violation of such sanctions programs. Without limiting the foregoing, you may not use the Services if (i) you are a resident, national or agent of a jurisdiction subject to comprehensive sanctions by OFAC (“Restricted Territories”), (ii) you are on the Table of Denial Orders, the Entity List, or the List of Specially Designated Nationals (“Restricted Persons”), or (iii) you intend to transact with any Restricted Territories or Restricted Persons.

In the event that we are required to block funds associated with your account in accordance with a sanctions program, or other similar government sanctions programs, we may: (i) suspend your account; (ii) terminate your account; (iii) return funds to the destination of their origin or to an account specified by authorities; or (iv) require you withdraw funds from your account within a certain period of time. In certain cases, taking one or more of these actions may result in a forfeiture of some or all of your assets held with ZSUITE GLOBAL INC. We are not responsible for any losses, whether direct or indirect, that you may incur as a result of our complying with applicable law and regulations, the guidance or direction of any regulatory authority or government agency, or any writ of attachment, lien, levy, subpoena, warrant, or other legal order.

Compliance

The company will establish a body responsible for the implementation of this policy. The company will carry out the procedure to identify any irregularity on behalf of any stakeholder under this policy. The company should;

  1. Identify all the financers of the company and verify their identity
  2. Take special care where stakeholders want anonymity
  3. Maintain proper records of the stakeholders

If anyone in the company knows or suspects that a person is involved in money laundering or terror financing, it is their responsibility to report such person to the body established by the company. In such a case, the company must

  1. Take the details of the people involved
  2. Verify the type of transactions
  3. Reason for suspicion
  4. The amount involved

The company must consult with the legal department before embarking on business with a third party and carefully screen such interactions.

The policy is subject to updates and amendments, which will be communicated to the stakeholder immediately.

Approved by:

JOHN RUSTIN