Legal Statements

our operating entities


Servy does business in various markets through local operating companies. The ‘Servy group’ and ‘Servy and affiliates’ refers to the collective of these operating companies.
 

Operating Company
United States of America
Cursus Technologies, Inc.
a Delaware corporation
Australia
Servy Technologies PTY LTD
an Australian proprietary company
Canada
Grab Technologies Inc.
a British Columbia corporation
European Union /
European Economic Area
Servy Technologies Limited
an Irish private limited company
United Arab Emirates
Servy MENA Portal LLC
a Dubai limited liability company
United Kingdom
Servy Technologies UK Limited
an English private limited company
company details
United States of America
FEIN: 46-5291232
Australia
ACN: 637 532 702
ABN: 37637532702
Canada
Incorporation No.: BC1204644
GST No.: 701148280BC0001
European Union /
European Economic Area
Company No.: 661066
VAT No.: IE 3667848PH
United Arab Emirates
License No.: 864989
United Kingdom
Company No.: 10614937
VAT No.: GB 276123995
Legal Address
United States of America
3302 Canal Street, Suite 13
Houston, Texas 77003
United States of America
Australia
Exchange Tower
Level 15, 2 The Esplanade
Perth, Western Australia, 6000
Australia
Canada
#202-1433 St. Paul Street
Kelowna, British Columbia, V1Y 2E4
Canada
European Union /
European Economic Area
Ulysses House
3rd Floor, 23/24 Foley Street
Dublin 1
Ireland
United Arab Emirates
Office Number 201
Emerald Building
Al Quoz Third
Dubai, United Arab Emirates
United Kingdom
6th Floor
9 Appold Street
London EC2A 2AP
United Kingdom

 anti-money laundering (“aml”) and counter-terrorist financing (“Ctf”) policy


Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions.

We have implemented systems and procedures that meet the and international and local AML legislation in the markets we serve. Our decision reflects our desire to prevent money laundering and not be used by criminals to launder proceeds of crime.

The regulatory frameworks which we follow are defined as:

Legal Framework
United States of America
Bank Secrecy Act - 31 USC 5311-5330
Foreign Assets Control Regulations (OFAC) - 31 CFR 500
Financial Record Keeping and Reporting of Currency and Foreign Transactions - 31 CFR 1010.310
USA PATRIOT Act
Australia
Anti-Money Laundering and Counter-Terrorism Financing Act 2006
Canada
Criminal Code and the Proceeds of Crime (Money Laundering)
Terrorist Financing Act (PCMLTA)
European Union /
European Economic Area
The Fourth Money Laundering Directive (AMLD)and Fund Transfer Regulation (FTR)
The Fifth Money Laundering Directive (5AMLD)
United Arab Emirates
Federal Law No. 4 of 2002, Concerning Combating Money Laundering and Terrorism Financing Crimes
Federal Law No. 1 of 2004, Decree on Combating Terrorism Offences
Federal Law No. 20 of 2018, On Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organizations
United Kingdom
The Proceeds of Crime Act (2002) (POCA) as amended by the Serious Organised Crime and Police Act 2005 (SOCPA) and the Proceeds of Crime Act (Amendment) Regulations 2007
The Terrorism Act 2000 as amended by the Anti Terrorism Crime & Security Act 2001, the Terrorism Act 2006, and the Terrorism Act (Amendment) Regulations 2007
The Money Laundering Regulations 2007
The Crime and Courts Act 2013
The Serious Crime Act 2015
The EU Fourth Money Laundering Directive (AMLD)and Fund Transfer Regulation (FTR)
The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector

Anti-Money Laundering (AML) Policy

The Servy AML Policy is designed to prevent money laundering by meeting the International and local AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

1. The appointment of a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules, and industry guidance;

2. Establishing and maintaining a Risk-Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;

3. Establishing and maintaining risk-based concession partner due diligence, identification, verification, and know your Payee (KYC) procedures, including enhanced due diligence for concession partners presenting higher risk, such as Politically Exposed Persons (PEPs);

4. Such KYC procedures are referred to as “Know Your Payee” (KYP) internally and are managed by Servy’s official payments facilitator, Hyperwallet, a service of PayPal;

5. Establishing and maintaining risk-based systems and procedures to monitor on-going customer and concession partner activity;

6. Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

7. The maintenance of appropriate records for the minimum prescribed periods; and

8. Training and awareness for all relevant employees.

 

Sanctions Policy

Servy is prohibited from transacting with concessions partners, owners of said concession partners, and countries that are on prescribed Sanctions lists. Servy will therefore screen against the sanctions lists of the US Office of Foreign Assets Control (OFAC), Dubai Financial Services Authority, United Nations, European Union, UK Treasury, and any further local similar such organizations in jurisdictions we operate.

Responsible Officer

The responsible party across the Servy group of companies and designated Anti Money Laundering Officer (AMLO) and Money Laundering Reporting Officer (MLRO) is:

Mark Bergsrud
Chief Executive Officer, Servy
mark@servy.us
+1 (832) 780-5700

The responsible party within the United Arab Emirates and designated Anti Money Laundering Officer (AMLO) and Money Laundering Reporting Officer (MLRO) for Servy MENA Portal LLC is:

Abdul Rahim Haja Mohideen
Director, Servy MENA
rahim@servy.us
+971 52 5766886