1. Policy Statement

PREMLIT (“we”, “our”, “us”) is committed to preventing money laundering, terrorist financing, fraud, and any misuse of its platform for unlawful financial activity.

We operate as a digital subscription access management platform and apply risk-based, proportionate AML controls aligned with the nature, scale, and complexity of our business.

PREMLIT does not operate as a bank, payment institution, or money service business and does not hold customer funds. All payments are processed by regulated third-party payment providers.

2. Legal & Regulatory Framework (United Kingdom)

PREMLIT’s AML practices are designed in accordance with applicable UK regulations and guidance, including:

• Proceeds of Crime Act 2002 (POCA)
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
• UK Financial Conduct Authority (FCA) risk-based guidance (where applicable)
• UK sanctions and financial crime obligations

PREMLIT applies AML controls proportionate to its role as a non-financial digital service provider.

3. Risk-Based Approach

PREMLIT adopts a risk-based AML approach, meaning:

• AML measures are applied based on transaction size, frequency, user behaviour, and risk indicators
• Enhanced controls are applied only where higher risk is identified
• Low-risk users are subject to simplified checks

This approach ensures compliance without unnecessary intrusion into legitimate user activity.

4. Customer Due Diligence (CDD)

4.1 Standard Due Diligence
For most users, PREMLIT performs basic due diligence, which may include:

• Account verification (email and basic identifiers)
• Monitoring transaction behaviour
• Review of usage patterns consistent with personal subscription access

PREMLIT does not require full identity documents from all users unless risk indicators arise.

4.2 Enhanced Due Diligence (EDD)
Enhanced checks may be applied where appropriate, including but not limited to:

• Unusual transaction frequency or volume
• Repeated refund or chargeback behaviour
• Indicators of account misuse, automation, or resale
• Requests from payment providers or legal authorities

Enhanced checks may include temporary account restrictions or additional verification requests.

5. Transaction Monitoring

PREMLIT monitors transactions and account activity to identify suspicious or abnormal patterns, including:

• Repeated failed payments
• Excessive refund requests
• Activity inconsistent with personal subscription usage
• Use of multiple accounts to bypass platform rules

Monitoring is conducted manually and through automated rules proportional to platform risk.

6. Suspicious Activity Handling

If suspicious activity is identified, PREMLIT may:

• Suspend or restrict the relevant account
• Decline or cancel a transaction
• Request clarification or verification from the user
• Cooperate with payment providers where required

PREMLIT reserves the right to take appropriate action without prior notice to protect platform integrity.

7. Reporting & Cooperation

PREMLIT will cooperate with:

• UK law enforcement authorities
• Regulatory bodies
• Payment service providers

Where legally required, PREMLIT will provide relevant information in accordance with UK law.

PREMLIT does not proactively file regulatory reports unless legally obligated to do so.

8. Record Keeping

PREMLIT retains relevant records in line with UK legal requirements, including:

• Transaction records
• Account activity logs
• Risk assessment outcomes

Records are retained only for as long as necessary for compliance, fraud prevention, and legal obligations.

9. Data Protection

All AML-related data processing is conducted in accordance with:

• UK GDPR
• Data Protection Act 2018
• PREMLIT Privacy Policy

Access to AML-related data is restricted to authorized personnel only.

10. Staff Awareness & Responsibility

PREMLIT ensures that individuals responsible for platform operations understand:

• Basic AML principles
• Fraud and abuse indicators
• Internal escalation procedures

Formal compliance roles are scaled in line with business growth.

11. Policy Review

This AML Policy is reviewed periodically and updated as necessary to reflect:

• Regulatory changes
• Business model evolution
• Risk profile adjustments

The latest version is always published on the PREMLIT website.

12. Contact

For AML-related inquiries, please contact:

compliance@premlit.com