Cot thsap SAMA NMBA EA DEEDAA EAA OEAA EMEA AM notte we sey blic of t 5 CC. ANTLMONEY LAUNDERING COUNCIL CERTIFICATE OF REGISTRATION This is to certify that WIRECARD E-MONEY PHILIPPINES, INC. has duly complied with the registration process of the Anti-Money Laundering Council (AMLC) for the purpose of submitting Covered and Suspicious Transaction Reports pursuant to the Anti-Money Laundering Act (Republic Act 9160), as amended, and its Revised Implementing Rules and Regulations. This certification is issued 22nd day of February 2019 in the City of Manila. MATTHEW M. DAVID Officer-in-Charge Control No.: BSP-20190219530008-0 COCA CC CE CEA ARACEAE AACA Eha CCEA E CROCK CREA IA ELAR PIIFIIIVE PVP OFFI D PPO OPIVE PIPPI IIISBANGKO SENTRAL NG FILIPINAS OFFICE OF THE ASSISTANT GOVERNOR SUPERVISION AND EXAMINATION SUB-SECTOR | LZ November 2017 Mr. Jeffrey Ho Kok Hoong President Wirecard e-Money Philippines, Inc. (WOEMPH) "Floor, Makati Sky Plaza, Brey. San Lorenzo 6788 Ayala Avenue 1223 Makati City Dear Mr. Hoong: Subject : Approval of License to Operate as Electronic Money Issuer (EMI) Please be informed that the Monetary Board (MB), in its Resolution No. 1889 dated 10 November 2017, granted approval of the request of Wirecard e-Money Philippines, Inc. to operate as an EMI, subject to the following conditions: 2 WDEPH shall strictly comply with the provisions and requirements of Section 4642N of the Manual of Regulations for Non-Bank Financial Institutions (MORNBF!) on the issuance and operations of electronic money. \WDEPH shall ensure the following: 2. Forms should accurately disclose the existing features/functionalities and loading limits of the e-money services; . Clear guidance in English and Filipino on consumers’ right of redemption, including conditions and fees for redemption; ‘c. Minimum systems and controls required by existing regulations should be in place, such as the establishment of an effective audit function, adoption of a comprehensive policy on outsourcing, and formalization of existing practices into written and Board-approved policies; 4d. Capability to monitor its inter-program exposures on a per cardholder basis at any given time, and performance of the same periodically; . Funding sources shall only be restricted to verified corporate clients’ bank accounts; £. Liquid assets shall fully cover the amount of outstanding e-money issued to Protect e-money holders and ensure that e-money redemptions are adequately met at all times; & Distributors/e-money agents shall comply with all applicable requirements of the Anti-Money Laundering (AML) laws, rules and regulations, Should there be third-party reliance for Know-Your-Customer (KYC} procedures, the same shallbe supported with a written certification in accordance with Circular No. 950 dated 15 March 2017; and h. Affected customers shall be informed that all e-wallet services are provided by WDEPH even if the existing prepaid card instruments bear the name of Citibank. The corresponding terms and conditions shall also reflect the same, The operation of e-wailet system outsourced to a service provider shall remain to be the responsibility of WDEPH, subject to adequate and regular review of internal and operational controls and observance of confidentiality of customer information in accordance with Republic Act (R.8.) No. 10173 (Data Privacy Act of 2012), Moreover, in outsourcing any e-wallet service, Section 4642N.11 of the MORNGFI shall be considered and complied with, On the outsourcing of IT services to Wirecard Technologies GmbH (WOT), WOEPH shall ensure compliance with the provisions of Section 4642N of the MORNBFI particularly on the required contract provisions, keeping of records and Preparation of reports, monitoring and review on an ongoing basis the Performance and delivery of outsourced IT services to WDEPH and ensuring that transactions made between WDEPH and WDT are kept at arms-length at all times. The offering of WOEPH e-wallet accounts shall comply with the existing AML laws, rules and regulations, including Circular No. 950 dated 15 March 2017. In this regard, WDEPH shall ensure the following, among others: a. The e-wallet shall not be used for money laundering or other illegal activities that will undermine the confidence of the public; > WOEPH shall report to BSP, through the Core Information Technology Specialist Group and Anti-Money Laundering Specialist Group, and Anti- Money Laundering Council any suspicious activity involving the use of its electronic services; and © The use of Information and Communication Technology (ICT) for the Conduct of face-to-face contact and interview, shall comply with Subsection 48060.2d of the above-cited circular. With respect to simplified KYC requirements for government. agencies, in Particular Pag-I8IG and SSS, WOEPH shall comply with the conditions for the approval granted to Citibank. WDEPH shall report crimes and losses to the BSP, through the Core IT Specialist Group (CITSG), involving e-money transactions whether consummated, frustrated OF attempted stage, inclusive of those which may be covered by RA. No. 8484 (The Access Devices Regulation Act of 1998) and/or R.A. No. $792 (The Electronic Commerce Act), WDEPH shall ensure compliance with the applicable provisions of the IT Risk Management Standards and Guidelines on Electronic Banking, Electro Page 206310. an. Payment, Electronic Money and Other Electronic Products and Services under Appendix 75f of Section 4196N. WDEPH shall adopt an Electronic Services Consumer Awareness Program, which, at the minimum, shall include consumers’ roles and responsibilities provided under Annex C of Appendix 75f of Section 4296N. WDEPH shall provide the Supervisory Data Center of the Supervision and Examination Sector, BSP, quarterly statements containing, among others, information on investments, volume of transactions, total outstanding e-money balances, and liquid assets in such form as may be prescribed later on. WDEPH shall notify the BSP, through CITSG, in writing at least thirty (30) days prior to its implementation of any change and/or enhancement in the product features and functionalities that may be made to WOEPH e-wallet services, as well as changes in WDEPHYs directors and key officers Very truly yours, RCE Assistant Gover Page 3 ofBANGKO SENTRAL NG PILIPINAS INTEGRATED SUPERVISION DEPARTMENT | BB suly 2018 Mr. Jeffrey Ho Kok Hoong President WIRECARD E-MONEY PHILIPPINES, INC. '5® Floor Makati Sky Plaza 6788 Ayala Avenue 1223 Makati City Dear Mr. Hoong: Subject: Issuance of Certificate of Registration Please be informed that the BSP has approved WIRECARD MONEY PHILIPPINES, INC.’s application to operate as a Remittance and Transfer Company (RTC) with principal address at 5® Floor Makati Sky Plaza, 6788 Ayala Avenue, Makati City with a Type “C" Electronic Money Issuer (EM) registration pursuant to Subsection 4511N.2 of the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI). Thus, the Issuance of the attached Certificate of Registration (COR) bearing MSB Registration No. '53-0008-00-000! subject to the following conditions: 1. All conditions set forth in BSP letter dated 27 November 2017 on the approval of WIRECARD E-MMONEY PHILIPPINES, INC. to operate as EMI, as well as those subsequent correspondences related thereto, where applicable, shall remain in effect; 2. WIRECARD E-MONEY PHILIPPINES, INC, shall ensure compliance, at all times, with the sworn statements made in the notarized Deed of Undertaking dated 16 April 2018 submitted in support of the subject application; 3, WIRECARD E-MONEY PHILIPPINES, INC. shall commence actual money service business operations within three (3) months from the date of issuance of the COR. Failure to commence actual business operations within the aforementioned three (3}-month period may result in the cancellation of the BSP registration as RTC; 4, WIRECARD E-MONEY PHILIPPINES, INC. shall notify the 8SP thru the Integrated Supervision Department | (ISD 1) in writing of the date of the start of operations within five (5) business days from the actual start of money service business operations; "With BS Repistered RA sticker with Contrel No. é- 9954 Which shall be isued once aval Fe/Rel Ma. SD1 201706 0289_GIOLLMSBWIRECARD EMONEY PHILIPINES, INC. Issuance of Ceruficate of Registration 5. WIRECARD E-MONEY PHILIPPINES, INC. shall ensure that the COR and the BSP registration sticker are displayed permanently in a conspicuous place within the office's premises; 6. WIRECARD E-MONEY PHILIPPINES, INC. is required to register with the Anti- Money Laundering Council Secretariat (AMLCS) pursuant to Subsection 4SLIN.2.d of the MORNBFi and shall submit to ISD | proof of registration with AMLCS within five (5) business days from registration. Failure to register within thirty (30) calendar days from the actual start of operations shall result in automatic cancellation of the BSP COR. in addition, the entity is required to report all covered (CTR) and suspicious (STR) transactions within five (5) business days from occurrence thereof pursuant to the provision of Part 8 of Q Regulations of the MORNBFI, in relation to Section 4104N of the ‘MORNBFI; 7. WIRECARD E-MONEY PHILIPPINES, INC. shall strictly comply with the provisions of Republic Act (R.A.) No. 9160, otherwise known as the Anti- Money Laundering Act of 2001, as amended and its revised implementing rules and regulations, in relation to Section 4104N of the MORNBFI; 8. WIRECARD E-MONEY PHILIPPINES, INC. shall maintain exclusive bank account/s in the name of the registered entity in its official business subject to BSP examination for Anti-Money Laundering purposes; 9. WIRECARD F-MONEY PHILIPPINES, INC. shall assume full responsibility to comply with all the requirements, rules and regulations of the BSP regarding the registration and notification of all its offices/branches, and its compliance with the registration requirements; 110. WIRECARD E-MONEY PHILIPPINES, INC. shall inform ISD 1, BSP of additional business activities pursuant to Memorandum No. M-2017-015 dated 31 March 2017; 11, WIRECARD E-MONEY PHILIPPINES, INC. shall adopt a system for promptly addressing the complaints of its customers in accordance with BSP Regulations on Financial Consumer Protection as provided under Sections 4701N and 4702N of the MORNBFI; 112. WIRECARD E-MONEY PHILIPPINES, INC. shall submit a new set of application in accordance with the provision in item ILA of Memorandum No. M-2017-014 dated 31 March 2017 in case of reclassification of registration category; 13, WIRECARD E-MONEY PHILIPPINES, INC. is subject to examination as determined by the BSP. Refusal to permit examination may result in the cancellation of the BSP COR; 14. WIRECARD E-MONEY PHILIPPINES, INC. shall ensure timely renewal of its business permit, which indicate the line of business, from the city or Page 20t3WIRECARD E-AAONEY PHILIPPINES INC. Issuance of Cerca of Registration municipality having territorial jurisdiction over the place of establishment and operation; and 15. Any violation of the foregoing conditions and other requirements stipulated under Section 4511N of the MORNGFI shall be subject to san to Subsection 4511N.15 thereof. ns pursuant Further, attached is the list of step-by-step procedures on how to register with AMILCS for your reference, Very truly yours, Att: A/S Page 3ot3Step-by-Step Procedure on how to Register with AMLC 1 2: Registration with the AMLC is via the Online Registration System (ORS). Before proceeding with the ORS, the Compliance Officers (Cos)/Primary Designated Officers (PDOs) should have document/s showing his/her designation, documents should be scanned and saved in PDF format. List of documents can be seen in the Online Registration manual which can be downloaded at wwiw.amle.gov.ph under the Services Menu — Registration Process. €0s/PD0s should download Transaction Security Protocol Manual at wnvw.amle.gov.oh, under the Services Menu ~ Registration Process and perform the following: 4) Install the GPG software; b) Generate Public key for CO/PDO; alternate’s public key is optional (Generated public key should be under the name of CO/PDO and alternate if available); ©) Export public key (file extension is asc) {Exported ase file will be needed in accomplishing the ORS); 4) Get and save the AMLC public key (amlc.ase) from www.amle.gov.oh under the Services Menu ~ Reporting Tools; €) Import the AMLC Public key (amic.asc); 4) Certify and sign the AMLC Public key; 8) Back-up CO/PDO's public key. Once items 2 and 3 have been accomplished, COs/PDOs can now log on to {nttps://portal.amlc.zov.oh and proceed with the Online Registration. Please make sure to regularly check the entered email address/es in the ORS, this will be validated by the system and this is where the approval of the Registration will be sent, Registration will be processed daily; cut-off time is 1:00 PM, registration received after 1:00 PM will be processed the following day. Attend the actual briefing on the preparation of the"CTR/STR reports, generation of public/private keys, encryption and electronic transmission of CSV formatted CTR/STR transaction files vie HTTP. Briefing is conducted at the AMLCS office once a month, Usually on the last Wednesday of the month. To register for the actual briefing please send an émail to imag@amlc.gov.ph, indicating your preferred date and the names of the company and participants. Questions, if any, may be emailed to imag@amlc.gov.oh. Response/s thereto shall be sent accordingly or you may call Mr. Conrad Bulanadi, Catherine Masaoay or Alvin Tolosa at (02) 302-3848, (02) 708-7923 or (02) 708-7064.BaNGKO SENTRAL NG PILIPINAS INTEGRATED SUPERVISION DEPARTMENT ! CERTIFICATE OF REGISTRATION MSB Registration No. 53-0008-00-000 WIRECARD E-MONEY PHILIPPINES, INC. STH FLOOR MAKATI SKY PLAZA, 6788 AYALA-AVENUE, MAKATI CITY is hereby registered to operate as a REMITTANCE and TRANSFER COMPANY (RTC) with a Type “C” E-MONEY ISSUER (EMI) registration in the Philippines, subject to the applicable provisions of law and Bangko Sentral ng Pilipinas rules and regulations,,as, well as. the provisions of the Anti-Money Laundering Act of 2001, as amended, and its revised implementing rules and regulations. Issued this 26" day of June 2018 in the City of Manila, Philippines. lbs Dil . SANTOS, Director: Rogpiis en