Anti-Money Laundering & KYC Policy

1. Policy Statement

Six Media Technology Limited is committed to the highest standards of Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") compliance. This policy outlines our procedures to prevent the use of our services for money laundering, terrorist financing, or other financial crimes, in accordance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) ("AMLO") of Hong Kong.

2. Regulatory Framework

Our AML program complies with:

• Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO)
• Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405)
• Organized and Serious Crimes Ordinance (Cap. 455)
• United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575)
• Financial Action Task Force (FATF) Recommendations
• Applicable international AML/CTF regulations

3. Know Your Customer (KYC) Procedures

3.1 Customer Identification

Before establishing a business relationship, we verify:

• Business registration certificate and incorporation documents
• Identity of directors, shareholders, and beneficial owners (>25% ownership)
• Government-issued photo identification for authorized persons
• Proof of business address
• Nature and purpose of the business relationship

3.2 Enhanced Due Diligence (EDD)

Enhanced measures apply to:

• High-risk jurisdictions identified by FATF
• Politically Exposed Persons (PEPs) and their associates
• Complex ownership structures
• Unusually large or frequent transactions
• Clients from sanctions-listed countries

4. Customer Due Diligence (CDD)

We conduct ongoing CDD including:

• Regular review and updating of customer information
• Screening against international sanctions lists (UN, OFAC, EU, HK)
• Monitoring transaction patterns for unusual activity
• Risk-based assessment of all business relationships
• Periodic reassessment of customer risk profiles

5. Transaction Monitoring

We employ systematic monitoring to detect:

• Transactions inconsistent with the customer's known business profile
• Unusual patterns of deposits, withdrawals, or fund transfers
• Transactions involving high-risk jurisdictions
• Structuring or splitting of transactions to avoid thresholds
• Rapid movement of funds with no apparent business purpose

6. Suspicious Activity Reporting

We maintain robust procedures for reporting suspicious transactions:

• Employees are trained to recognize indicators of money laundering and terrorist financing
• Suspicious Transaction Reports (STRs) are filed with the Joint Financial Intelligence Unit (JFIU) of Hong Kong
• Reports are made promptly and confidentially
• Tipping off is strictly prohibited

7. Record Keeping

We maintain comprehensive records for a minimum of 6 years including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• Internal and external correspondence relating to CDD
• Risk assessments and monitoring reports
• Staff training records

8. Staff Training

All relevant employees receive regular AML/CTF training covering:

• Legal obligations and regulatory requirements
• Customer identification and verification procedures
• Recognition of suspicious activities and red flags
• Internal reporting procedures
• Updated typologies and emerging risks

9. Compliance Officer

Our designated Money Laundering Reporting Officer (MLRO) oversees all AML/CTF activities and can be contacted at info@sixmedia.hk.

10. Contact