EMAR LIBYA LTD is committed to preventing misuse of its services for money laundering, terrorist financing, fraud, sanctions evasion and other financial crime. This framework sets out the controls the company intends to maintain, proportionate to the risks, products, countries and regulatory obligations applicable to each activity. It does not represent a claim of regulatory licensing or third-party certification.
The company adopts a risk-based approach informed by the Financial Action Task Force (FATF) Recommendations and, where applicable, UK anti-money laundering, sanctions, data protection and financial-crime requirements, together with applicable rules in operating jurisdictions and the requirements of licensed issuing and payment partners. Regulatory obligations are determined by the actual services and legal entities involved. The company will identify responsible personnel, document decisions, review controls periodically and obtain qualified legal advice when required.
Before enabling relevant financial services, the company will collect and assess appropriate identification and contact information, which may include full legal name, date of birth, nationality, residence, phone number, government-issued identification and evidence of address. Verification may involve manual review and/or approved identity-verification providers. The company will reject or restrict applications when identity cannot be satisfactorily established, information is inconsistent, or a partner's eligibility rules are not met.
For business customers or counterparties, due diligence may include registration documents, legal status, operating address, directors, authorized representatives, ownership and control structure, ultimate beneficial owners, intended account purpose and source of funds. Enhanced checks apply where ownership or control cannot be reliably established.
Customer and transaction risks will be evaluated using relevant factors including geography, product, delivery channel, transaction behavior, payment method and adverse information. Higher-risk relationships may require additional documents, source-of-funds or source-of-wealth evidence, senior approval, tighter limits or increased monitoring. The company reserves the right to refuse, suspend or terminate relationships where risk cannot be appropriately mitigated.
Where required by law or issuing partners, customers, beneficial owners and relevant counterparties will be screened against applicable sanctions lists and assessed for politically exposed person (PEP) exposure and material adverse information. Potential matches must be reviewed rather than treated as confirmed solely on the basis of a name similarity. Prohibited persons, territories and activities will be restricted in accordance with applicable rules. Customer residence or nationality alone is not represented as automatic eligibility for card issuance.
The company will apply risk-appropriate transaction controls, which may include payment confirmation, review of unusual transaction patterns, velocity and value limits, duplicate or inconsistent payment detection, manual escalation and review of chargebacks or failed transactions. Activity that is inconsistent with a customer's known profile or suggests structuring, third-party misuse or sanctions evasion may trigger further investigation and temporary restrictions.
Where digital-asset funding is permitted by the relevant service provider and applicable law, the company will assess associated risks and apply appropriate controls, including verification of the funding route and enhanced review where necessary. Acceptance of USDT or any other digital asset is subject to product-specific permissions, sanctions restrictions, partner policies and legal requirements. The company does not claim to provide regulated cryptoasset services unless separately authorized where required.
Any Visa or Mastercard products offered through Trevo or related services are subject to the approval, KYC standards, country restrictions and ongoing requirements of the licensed issuer, program manager and relevant network. EMAR LIBYA LTD will not represent itself as a licensed bank or card issuer unless duly authorized. The company will cooperate with its partners on onboarding, monitoring, investigations, dispute management and account restrictions.
Employees and authorized operators must escalate potentially suspicious activity to the designated compliance contact without notifying the subject inappropriately. Reports to competent authorities will be made when legally required, through the appropriate reporting channel and responsible entity. The company will preserve relevant evidence and cooperate with lawful requests while respecting confidentiality and data-protection obligations.
Customer due diligence records, transaction evidence and investigation records will be retained for the period required by applicable law and partner contracts, subject to data-minimization and secure-deletion obligations. Access will be limited to authorized personnel; reasonable technical and organizational measures will be used to protect information. Customers' personal data will be handled under the applicable privacy notice and data-protection rules.
Personnel performing onboarding, payment review or customer support will receive role-appropriate guidance on identifying red flags and escalating concerns. The company will periodically assess whether controls remain effective and update this policy in response to changes in products, applicable laws, risk exposure or partner requirements. Independent assessment will be arranged where required or appropriate.
The company prohibits knowingly facilitating fraud, identity misuse, sanctions evasion, money laundering, terrorist financing, unauthorized third-party card use and other illegal transactions. Services may be delayed, refused, limited or terminated where compliance checks are incomplete or risk thresholds are exceeded, subject to applicable law and contractual obligations.
For compliance-related enquiries, contact support@emarlibya.net. Please do not send identity documents by ordinary email unless a secure submission method has been agreed.
This public-facing policy summary is not a substitute for internal operating procedures, regulatory authorizations, or an issuer's onboarding approval. The final approved version should be dated, assigned to an accountable owner and reviewed against actual operational controls before publication.
