Anti-Money Laundering Policy
Fierylee ("we," "us," or "our") is committed to conducting business with integrity and transparency, and to full compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) laws and regulations in the jurisdictions where we operate. This policy outlines the fundamental framework and procedures we have established to prevent our platform and services from being used for money laundering or terrorist financing activities.
1. Policy Statement and Commitment
We are unequivocally committed to not knowingly participating in or facilitating money laundering, terrorist financing, or any other illicit financial activity. We maintain a risk-based internal control framework designed to effectively identify, assess, monitor, report, and mitigate associated financial crime risks.
2. Risk-Based Approach and Geographic Restrictions
We employ a risk-based approach to implementing this policy. This means we concentrate our resources on higher-risk customers, transactions, products, and geographies.
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2.1 Sanctioned & High-Risk Jurisdictions: To comply with international sanctions and mitigate risk, we strictly prohibit direct shipments to comprehensively sanctioned or unilaterally determined high-risk countries/regions (including but not limited to Iran, North Korea, Crimea region, Syria, Cuba). Relevant orders will be intercepted and cancelled by our system or manual review during the payment or logistics process.
3. Customer Identification and Due Diligence (CDD)
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Verification of Identity: In accordance with legal requirements and our internal risk assessment, we may require users to provide identification information for verification under specific circumstances (e.g., transactions meeting certain thresholds, suspicious behavior, or doubts about a customer's identity). This may include, but is not limited to: full name, residential address, date of birth, a government-issued photo ID (e.g., passport, driver's license), and proof of address.
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Payment Monitoring: We monitor payment behaviors and do not accept clearly abnormal patterns, such as: a single order paid with multiple credit cards under different names, a single user utilizing a large number of different shipping addresses, or frequent payment failures followed by a successful transaction. Such activities will trigger stringent review.
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Right to Refuse: We reserve the right to decline to establish a business relationship or process transactions for individuals or entities who fail to provide sufficient identification or are found to be associated with illicit activities.
4. Transaction Monitoring
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Monitoring Mechanism: We utilize a combination of automated systems and manual review to conduct ongoing monitoring of transaction activities on our platform to identify unusual or suspicious patterns that may indicate money laundering or terrorist financing.
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High-Value Transaction Review: We have set a monitoring threshold of single transaction value ≥ USD 1,000. Orders meeting or exceeding this threshold will automatically trigger a manual review process. During this review, if we identify unexplainable anomalies in order details, payment methods, or customer behavior, we reserve the right to refuse shipment and arrange a full refund.
5. Record Keeping
We will retain all customer identification records, due diligence materials, complete order and payment receipts. These records will be retained for a minimum of five years from the completion of the transaction or the termination of the business relationship, as required by law.
6. Suspicious Transaction Reporting (STR)
Where we have reasonable grounds to suspect that a transaction or activity is related to money laundering or terrorist financing, we will promptly file a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit (FIU) or competent authority as required by law. We will adhere strictly to "tipping-off" prohibitions and will not disclose the report to the customer in question.
7. Employee Training and Awareness
We ensure that all relevant employees, particularly those in compliance, finance, customer service, and sales roles, receive regular and appropriate AML/CFT training. This training ensures they are aware of current risks, legal obligations, company policies, and how to identify and escalate suspicious activity.
8. Policy Review and Update
This policy will be reviewed regularly (at least annually) and updated promptly in response to significant changes in laws or regulations, or material changes to our business model or risk profile, to ensure its continued effectiveness and compliance.
9. Responsibility and Contact
Company management bears final responsibility for the effective implementation of this policy. If you have any questions regarding this policy or wish to report any activity related to Fierylee that you find suspicious, please contact our Compliance Officer.
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