AML/CFT and financial crime policy
Version 2026-10-07.7
1. Operator and contact
ZergPay is operated by ZERG GLOBAL CORP PSP - FZCO, registration number 83468, Dubai Silicon Oasis, Dubai, United Arab Emirates. Website: https://zergpay.com. Contact: Info@zergpay.com. Company registration details are not a representation of authorisation to provide a particular regulated financial service.
2. Scope and principles
This policy describes the approach to preventing money laundering, terrorist financing, evasion of applicable sanctions, fraud and other financial misuse. Controls are proportionate to business and risk. International principles inform the approach; specific duties depend on applicable law and participant roles, not a claimed uniform worldwide regime.
3. Risk assessment
Assessment considers business model, products and services, participant and transaction geography, ownership, sales channels, payment methods, expected activity and evidence quality. A single factor does not always determine the result: circumstances are considered together, with decisions and required measures recorded.
4. Due diligence
Before relevant services are enabled, the business, representatives and beneficial owners are established to the required extent. Understanding the relationship’s purpose and expected activity supplements document checks. Simplified measures require justified low risk and permission under applicable rules; they are not used where misuse is suspected.
5. Enhanced measures
Higher risk may require additional independent evidence, source-of-funds or wealth enquiries, detailed business explanations, approval by an authorised senior reviewer and closer monitoring. PEP status calls for risk assessment, not an automatic finding that activity is unlawful.
6. Sanctions and restrictions
Restrictions applicable to the operator, partners and particular relationship are assessed. Potential matches are reviewed using identifiers, control structures and context. Concealing participants or rerouting activity to evade restrictions is prohibited. Blocking, freezing or authority reporting requires the relevant legal basis.
7. Transaction monitoring
Activity is compared with the declared business model. Review triggers may include unexplained volume changes, structuring, unusual refunds, pass-through funds, payer-beneficiary inconsistencies, apparent sham sales or compromised access. An alert is a reason for review, not a finding of wrongdoing.
8. Investigation and reporting
The authorised team reviews facts, requests explanations and determines appropriate action. Where reporting to a competent authority is legally required, the responsible obligated participant makes that report. Details may be withheld where disclosure is prohibited or risks an investigation. This policy does not prescribe one reporting deadline or authority for every country.
9. Restrictions and cooperation
Where necessary, methods, limits or operational access may be restricted within legal and contractual boundaries. Merchants must provide truthful explanations and preserve relevant records. Inaccurate information may be corrected and decisions submitted for review through Info@zergpay.com, subject to restrictions on disclosure.
10. Governance and retention
Access to reviews is based on operational need. The approach includes assigned responsibilities, training of authorised staff, recorded decisions and reassessment as risks change. Records are retained for applicable mandatory periods and necessary dispute periods, then deleted or anonymised unless another lawful basis applies.
11. Operator details
Legal entity: ZERG GLOBAL CORP PSP - FZCO. Registration number: 83468. Trade License No.: 90237. Registered address: DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates. Website: https://zergpay.com. Email: Info@zergpay.com.