Compliance Document

Anti-Money Laundering (AML) Policy

SAP-Algo's commitment to preventing financial crime and maintaining regulatory compliance.

Last updated: April 7, 2026

SAP-Algo is Committed to AML & CFT Compliance
We implement robust controls to detect, prevent, and report money laundering, terrorist financing, and other financial crimes โ€” in accordance with applicable international standards and the laws of the Republic of Indonesia.
1. Purpose & Scope

This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy establishes SAP-Algo Technologies' commitment to and framework for combating financial crime across all its operations, platforms, and payment channels โ€” including cryptocurrency transactions processed via CoinPayments.

This policy applies to:

  • All users and customers transacting on the SAP-Algo platform.
  • All employees, contractors, and partners of SAP-Algo Technologies.
  • All payment transactions, including those made in fiat and cryptocurrency.
  • All geographical regions in which SAP-Algo operates or accepts customers.
Regulatory Basis: This policy is informed by Indonesian Law No. 8 of 2010 on the Prevention and Eradication of Money Laundering, FATF (Financial Action Task Force) Recommendations, and applicable international anti-financial crime standards.
2. Key Definitions
  • Money Laundering (ML): The process of making illegally obtained funds appear legitimate through a series of financial transactions.
  • Terrorist Financing (TF): Providing financial support for terrorist activities or organizations, regardless of whether the funds originate from legal or illegal sources.
  • Know Your Customer (KYC): The process of verifying the identity of customers and assessing their risk profile before and during the business relationship.
  • Suspicious Activity Report (SAR): A report filed with relevant authorities when suspicious transaction activity is identified.
  • Politically Exposed Person (PEP): An individual who holds or has held a prominent public function, and whose transactions warrant enhanced scrutiny.
  • Beneficial Owner: The natural person who ultimately owns or controls a customer entity or on whose behalf a transaction is conducted.
3. Risk-Based Approach

SAP-Algo employs a risk-based approach to AML compliance, allocating resources proportionately to the level of risk identified. We assess money laundering risk across three levels:

Low Risk
Standard customers, small transactions, known jurisdictions, clean transaction history.
Medium Risk
New customers, high-value single transactions, or unusual activity patterns.
High Risk
PEPs, high-risk jurisdictions, anonymizing tech, or transactions flagged by CoinPayments.

Higher-risk profiles receive enhanced due diligence (EDD), including additional identity verification and transaction monitoring.

4. Know Your Customer (KYC) Procedures

SAP-Algo implements KYC verification proportionate to transaction value and risk profile. Our KYC process includes the following tiers:

1
Basic Verification (All Users)
Name, email address, country of residence, and MetaTrader account number. Verified via registration and account confirmation.
2
Enhanced Verification (High-Value / Flagged Transactions)
Government-issued ID (passport or national ID), proof of address (utility bill or bank statement), and source of funds declaration. Triggered for transactions above USD 3,000 equivalent or when flagged by our risk engine.
3
PEP / High-Risk Enhanced Due Diligence
Additional background screening, senior management approval, and ongoing enhanced monitoring for politically exposed persons and high-risk jurisdictions.
Note: CoinPayments applies its own KYC/AML checks on cryptocurrency transactions. SAP-Algo cooperates with CoinPayments' compliance requirements and may restrict or halt services pending CoinPayments' verification outcomes.
5. Prohibited Activities & Transactions

The following activities are strictly prohibited on the SAP-Algo platform:

  • Transactions involving proceeds of criminal activity, fraud, or corruption.
  • Payments originating from or destined to sanctioned individuals, entities, or countries (OFAC, UN, EU sanctions lists).
  • Use of mixing services, tumblers, or anonymizing tools to obscure the origin of cryptocurrency funds.
  • Use of the platform on behalf of undisclosed third parties or beneficial owners.
  • Structuring transactions to avoid reporting thresholds (smurfing).
  • Any activity related to financing terrorism, proliferation of weapons, or other illegal activities.
  • Creation of multiple accounts to circumvent AML/KYC requirements.
Consequences: Violations of this policy will result in immediate suspension of services, forfeiture of any associated funds (to the extent permitted by law), filing of a Suspicious Activity Report (SAR) with the relevant financial intelligence unit, and potential referral to law enforcement authorities.
6. Transaction Monitoring & Suspicious Activity

SAP-Algo monitors all transactions on our platform for suspicious activity. Red flags that may trigger enhanced review include:

  • Transactions that are inconsistent with a customer's known profile or transaction history.
  • Multiple transactions just below reporting thresholds in a short period.
  • Use of high-risk cryptocurrencies known for anonymization (privacy coins).
  • Customers who are reluctant to provide identification or source-of-funds information when requested.
  • Transactions originating from IP addresses in sanctioned or high-risk jurisdictions.
  • Rapid layering โ€” moving funds quickly through multiple wallets or currencies.
  • Payments flagged or blocked by CoinPayments' own AML screening systems.

When suspicious activity is identified, SAP-Algo will freeze the associated transaction pending review and, where required by law, file a report with Indonesia's PPATK (Pusat Pelaporan dan Analisis Transaksi Keuangan) or equivalent authority.

7. Sanctions Compliance

SAP-Algo screens all customers and transactions against applicable international sanctions lists, including:

  • OFAC (Office of Foreign Assets Control) โ€” United States
  • UN Security Council Consolidated Sanctions List
  • EU Consolidated Financial Sanctions List
  • Indonesia's national sanctions and designated terrorist list (DTTOT)
  • Other applicable regional or bilateral sanctions regimes
Blocked Jurisdictions: SAP-Algo does not accept customers from FATF-identified high-risk jurisdictions, OFAC-sanctioned countries, or other regions subject to comprehensive international sanctions. This list may be updated without prior notice as regulatory situations change.
8. Record Keeping

SAP-Algo maintains comprehensive records of all customer due diligence information, transaction data, and compliance decisions in accordance with applicable law:

  • KYC documentation and identity verification records: retained for a minimum of 5 years after the end of the business relationship.
  • Transaction records (including CoinPayments TXIDs, amounts, and timestamps): retained for a minimum of 5 years from the date of the transaction.
  • Suspicious Activity Reports (SARs) and supporting evidence: retained for a minimum of 5 years from the date of filing.
  • All records are stored securely and are available to authorized law enforcement or regulatory authorities upon lawful request.
9. Training & Responsibility

SAP-Algo is committed to maintaining a culture of compliance through:

  • Regular AML/CTF training for all personnel with access to customer data or payment systems.
  • Designation of an AML Compliance Officer responsible for overseeing the implementation of this policy.
  • Periodic internal audits and policy reviews (at minimum annually) to ensure the policy remains effective and up to date.
  • A confidential internal reporting mechanism for employees to raise AML concerns without fear of retaliation.
10. Reporting Concerns & Contact

If you have reason to believe that a transaction or activity on the SAP-Algo platform involves money laundering, fraud, or other financial crime, please report it immediately:

  • Email: compliance@sapalgo.com
  • Support: support@sapalgo.com
  • Indonesian Financial Intelligence Unit: www.ppatk.go.id

This policy is reviewed and updated at minimum annually, or more frequently in response to regulatory changes. All users are bound by the most current version of this policy.