1. Purpose and scope
Registered office (Nevis)
OmertaCall LLC, Hunkins Waterfront Plaza, Suite 556, Main Street, Charlestown, Nevis.
EU establishment (Dublin, Ireland)
OmertaCall (Irish branch of OmertaCall LLC), Office Suites Club, 20 Harcourt St, Saint Kevin's, Dublin 2, D02 H364, Ireland.
OmertaCall LLC sets this policy to prevent its telecommunications services from being used to launder criminal proceeds or finance terrorism. Money laundering disguises the source or ownership of proceeds of crime. Terrorist financing supplies funds or resources for terrorism, including funds that originally came from lawful activity.
This policy sets requirements for client acceptance, payments, number provision and relevant supplier and reseller relationships. An invitation does not replace identity checks or create a right to service. Requirements imposed by applicable law take precedence over this public policy.
2. Risk-based approach
Compliance decisions must consider the client's business, ownership, countries of operation, intended traffic, payment methods and distribution arrangements together. A single nationality or payment method is not sufficient to establish wrongdoing. Staff must assess the evidence and document the reasons for the risk rating.
The assessment must be revisited when ownership, payment patterns, destinations or service use materially change, and before introducing products or processes that create new financial-crime exposure. Unresolved identity, sanctions or lawful-use concerns must be escalated before service is activated or expanded.
3. Customer due diligence and KYC
KYC forms part of onboarding. Before accepting a client, the responsible team must establish and verify the legal identity of the business, its registration and business address, the people authorised to act for it, and the natural persons who ultimately own or control it. Verification must use reliable documents or independent sources appropriate to the risk.
The file must explain the purpose of the account, expected services and traffic, payment arrangements and, where relevant, the client's authority to resell numbers or services. Clients must provide accurate information and notify OmertaCall of material changes. Missing, inconsistent or unverifiable information may result in delayed onboarding or refusal of service.
4. Enhanced due diligence
Higher-risk relationships require additional evidence and approval by the AML Compliance Officer before acceptance or continuation. Measures may include examining ownership chains, establishing the source of funds and, where appropriate, source of wealth, checking the commercial rationale, and increasing the frequency of reviews.
Politically exposed persons, complex ownership without a clear business explanation, high-risk jurisdictions and adverse information require a proportionate assessment. Staff must not treat a screening match as a confirmed identity without reviewing the supporting information.
5. Sanctions screening
Screening must cover clients, beneficial owners and relevant counterparties at onboarding and before number assignment or payments out, including refunds. Checks must consider applicable sanctions, including relevant United Nations, United States OFAC, European Union and United Kingdom lists, and be refreshed when lists or relationship details change.
Potential matches must be referred to the AML Compliance Officer for investigation. Staff must not activate prohibited service, release restricted funds or help circumvent restrictions. Any blocking, freezing or reporting action must follow the law applicable to the relationship.
6. Ongoing monitoring
Reviews must compare account activity with the declared business and expected payment and traffic patterns. Warning signs include unexplained prepaid balance cycling, crypto top-ups inconsistent with the stated business, requests to refund a different person or payment instrument, and undisclosed number reselling. These are reasons to investigate, not automatic findings of criminal activity.
Staff must seek clarification where lawful, retain the assessment and escalate unresolved concerns. Measures may include additional verification, limits, suspension or termination, subject to contractual and legal requirements. Monitoring must remain proportionate and respect the privacy obligations described in the Privacy Policy.
7. Suspicious activity reporting
Staff must promptly report suspected money laundering, terrorist financing or sanctions evasion to the AML Compliance Officer, who performs the Money Laundering Reporting Officer role. External concerns can be directed to [email protected] with the subject “AML concern”. Do not send identity documents or sensitive payment details in an initial email; request a secure submission method.
The officer must assess the information, document the decision and make any legally required suspicious activity report to the competent authority, including the Financial Intelligence Unit of Saint Kitts and Nevis where applicable. Internal escalation does not replace statutory reporting. Staff must preserve evidence and must not disclose a report or investigation where doing so would constitute unlawful tipping off. OmertaCall may be unable to explain a restriction or confirm that a report exists.
8. Record keeping
The policy standard is to retain identity and due-diligence records for at least five years after the relationship ends, and relevant transaction records for at least five years after the transaction, subject to applicable legal requirements. A longer mandatory period or lawful preservation requirement takes precedence. This standard concerns compliance records; it does not set the retention period for call recordings or transcripts.
Records must support reconstruction of decisions and transactions, be accessible only to authorised personnel and be securely deleted when the applicable retention period and any legal hold end.
9. Training and governance
Senior management is responsible for providing resources and oversight. The AML Compliance Officer is responsible for the risk framework, escalations and reporting decisions. Relevant staff must receive induction and periodic refresher training on identification, sanctions, telecom-specific warning signs, confidential reporting and record handling.
The programme must be reviewed periodically and after material incidents or legal changes, with independent review proportionate to the risks. Findings must have an accountable owner and corrective actions. This statement describes policy requirements; it is not an assertion that an independent AML audit has been completed.
10. Contact and related policies
Legal questions about this policy should be sent to [email protected] or addressed to OmertaCall LLC at the Nevis address above. Read this policy alongside the Privacy Policy, Terms of Service and Acceptable Use Policy. Updated requirements will be published on this page with a revised date.