1.Overview
Zilligo Payments LTD ("Zilligo") is committed to preventing money laundering and terrorist financing. This policy outlines the controls we maintain as a payment services company registered in Mauritius (File No. C215482).
2.Risk-based approach
Zilligo operates a risk-based AML program calibrated to our business model. As a payment bridge rather than a custodial institution, our exposure to certain AML risks differs from traditional financial institutions. We assess the risk profile of our services and implement controls proportionate to those risks.
3.Transaction monitoring
All orders are reviewed by a real team member before processing. We monitor for unusual patterns, including unusually large orders, rapid succession of orders to the same destination, or patterns inconsistent with legitimate use. Suspicious activity may result in order cancellation and, where legally required, reporting to relevant authorities.
4.Prohibited uses
Zilligo services may not be used for money laundering, financing of terrorism, proceeds of criminal activity, sanctions evasion, or any other illegal purpose. Orders that we reasonably believe violate these prohibitions will be cancelled and funds may be returned at our discretion less any applicable fees.
5.Record keeping
We maintain records of all transactions for a minimum of 5 years as required by applicable regulations. Records include order amounts, destinations, timestamps, and transaction references. Personal identity documents are not collected as part of our standard service.
6.Staff training
All team members who process orders are trained on AML obligations, red flags for suspicious activity, and reporting procedures. Training is updated annually.
7.Reporting
Where required by law, we will report suspicious activity to the appropriate financial intelligence unit in our jurisdiction. We cooperate fully with legitimate law enforcement requests accompanied by appropriate legal process.
8.Contact
AML compliance questions can be directed to our team via the Contact page. We take all compliance concerns seriously and respond promptly.
Questions about this policy? Write to us through the contact page, and include your order ID if it is about an order.