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. 

 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:

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