Anti-Money Laundering, Counter-Terrorist Financing and goAML Compliance Policy

Anti-Money Laundering, Counter-Terrorist Financing and goAML Compliance Policy

Last updated: July 2026

1. Our Commitment

Amigo Treks & Expedition P. Ltd. is committed to conducting its travel, trekking, tour and expedition business honestly, responsibly and transparently.

We do not knowingly accept, process or assist with payments connected to money laundering, terrorism financing, fraud, corruption, sanctions evasion, human trafficking or any other unlawful activity.

We maintain reasonable customer-verification, payment-review, record-keeping and reporting controls to protect our guests, business partners, employees and the wider financial system.

This policy explains the standards we follow when accepting bookings, receiving payments, issuing refunds and working with customers, travel agents, suppliers and other business partners.

2. Scope of This Policy

This policy applies to:

• Individual travellers and group members

• Persons making payments on behalf of travellers

• Corporate and institutional customers

• Overseas and domestic travel agents

• Tour operators and destination-management companies

• Guides, suppliers, hotels, transport providers and contractors

• Directors, employees, representatives and authorised agents of Amigo Treks & Expedition

The policy applies to payments received through banks, cards, approved online payment services, licensed remittance channels, cash and any other payment method accepted by us.

3. Compliance With Nepalese Law

We conduct our business in accordance with applicable laws, regulations, directives and guidance issued by the Government of Nepal, Nepal Rastra Bank, the Financial Intelligence Unit of Nepal and other competent authorities.

Where our activities fall within foreign-exchange or financial-reporting requirements, we follow the conditions of our licence and the applicable regulatory instructions.

We may update this policy whenever legal requirements, regulatory guidance, payment methods or our business activities change.

4. Customer Identification and Verification

We may request information and documents needed to confirm the identity of a traveller, customer, payer or business partner.

Depending on the booking and level of risk, this may include:

For individual customers

• Full legal name

• Nationality

• Date of birth

• Residential address

• Telephone number and email address

• Passport, citizenship certificate or other government-issued identification

• Travel dates and itinerary

• Name and relationship of the person making the payment

• Information about the source or purpose of funds, where necessary

For companies and travel partners

• Registered business name

• Registration and tax details

• Registered address

• Names of directors, owners or authorised representatives

• Proof of authority to act for the company

• Bank-account information

• Details of the persons who ultimately own or control the business

• Nature and purpose of the business relationship

We may verify submitted information through reliable documents, official records, payment providers or other lawful sources.

5. Beneficial Ownership

Where a booking, payment or business relationship involves a company, trust, partnership, agent or another person acting for someone else, we may ask for information about the individual who ultimately owns, controls or benefits from the transaction.

We may decline or delay a transaction when the true customer, payer or beneficial owner cannot be reasonably identified.

6. Risk-Based Review

Not every booking presents the same level of financial or compliance risk. We apply additional checks where a transaction, customer or payment arrangement requires closer review.

Factors that may result in additional verification include:

• A payment made by an unrelated third party

• A payer whose name does not match the traveller or booking party

• Unusual payment or refund instructions

• Multiple payments from different persons or accounts

• Requests to transfer a refund to a different account

• Unexplained overpayments

• Frequent booking changes without a clear travel purpose

• Payments involving higher-risk locations or restricted persons

• Corporate ownership that is unusually complex or unclear

• Reluctance to provide reasonable identification or payment information

• Transactions that appear inconsistent with the stated travel arrangements

The presence of one factor does not automatically mean that unlawful activity has occurred. It may, however, require us to request additional information before proceeding.

7. Politically Exposed Persons and Sanctions Screening

Where appropriate, Amigo Treks & Expedition may screen customers, payers, beneficial owners and business partners against relevant sanctions, restriction and politically exposed person records.

A politically exposed person is not automatically prohibited from booking with us. However, additional verification, management approval and information about the source of funds may be required.

We will not knowingly provide services to a person or organisation where doing so would violate applicable sanctions or legal restrictions.

8. Payments

Payments must normally be made:

• By the traveller named in the booking;

• By the person or organisation responsible for the group;

• By an authorised travel agent or business partner; or

• By another person whose relationship to the traveller has been satisfactorily explained.

Payments must be made through lawful and traceable channels approved by Amigo Treks & Expedition.

Customers should use the booking reference, invoice number or traveller’s name when making a payment.

We may request proof of payment, bank confirmation, payer identification or an explanation of the relationship between the payer and traveller.

We do not encourage customers to divide one payment into several smaller payments to avoid banking, identification or reporting requirements.

9. Cash and Foreign-Currency Transactions

Cash and foreign-currency transactions are accepted only where permitted by law and by our applicable licence conditions.

When accepting cash or foreign currency, we may:

• Verify the customer’s identity

• Issue an official receipt

• Record the currency, amount, date and purpose

• Request supporting travel or booking documents

• Apply additional checks where legally or operationally required

• Deposit or account for the funds through authorised channels

Amigo Treks & Expedition reserves the right to refuse a cash or foreign-currency payment and request payment through a bank or another approved method.

10. Third-Party Payments

A third-party payment is a payment made by someone other than the traveller or organisation named in the booking.

We may accept a third-party payment when there is a legitimate and clearly explained reason, such as payment by:

• A family member

• An employer

• A recognised travel agent

• A tour operator

• A sponsoring organisation

• A group leader

We may require identification from the payer and evidence of the relationship between the payer and traveller.

We may reject a third-party payment when the relationship or purpose cannot be reasonably verified.

11. Refunds and Overpayments

Approved refunds are normally returned to the original payment method and the original payer.

We generally do not:

• Refund money to an unrelated third party

• Send a refund to an account different from the original payment account without satisfactory justification

• Convert an overpayment into a transfer to another person

• Use a booking or cancellation as a method of moving money between persons or countries

Where the original payment method is no longer available, we may request additional documents and management approval before processing the refund.

Refunds remain subject to our booking, cancellation and refund terms.

12. Suspicious Transactions and Activities

Amigo Treks & Expedition reviews unusual transactions and activities in accordance with its internal compliance procedures.

A transaction may require review when its amount, payment method, payer, refund instruction, timing or stated purpose does not reasonably match the booking or customer profile.

Where required by applicable law or regulatory instructions, we may submit information to the relevant authority through the prescribed reporting system, including goAML.

We are not permitted to inform a customer that a confidential suspicious transaction or activity report has been made or is being considered.

Submitting a report does not mean that we have accused a customer of committing an offence. It means that the matter has been referred to the competent authority for appropriate assessment.

13. Transaction Reporting

Certain transactions may be subject to regulatory reporting depending on:

• The nature of the transaction

• The payment or foreign-exchange activity involved

• Our applicable licence category

• The legally prescribed threshold

• Current exemptions or instructions issued by the relevant regulator

A tour, trekking or expedition payment is not treated as a reportable threshold transaction solely because it is of a particular value. The applicable legal and regulatory conditions must also be considered.

Where reporting is required, Amigo Treks & Expedition will submit the relevant information within the prescribed period and format.

14. Record Keeping

We maintain appropriate records relating to bookings, customer identification, payments, refunds, invoices, correspondence and compliance reviews for the period required by applicable law and our internal record-retention procedures.

Records may be kept in physical or electronic form and may include:

• Customer and traveller details

• Identification documents

• Booking and itinerary records

• Invoices and receipts

• Payment and refund records

• Agent or business-partner documents

• Internal approvals and compliance-review records

• Reports and communications submitted to competent authorities

Access to these records is limited to authorised persons with a legitimate business, legal or compliance need.

15. Information Sharing

We may disclose relevant information where necessary to:

• Process a booking or payment

• Verify a customer or payer

• Prevent fraud or financial crime

• Meet a legal or regulatory requirement

• Respond to a lawful request from a competent authority

• Protect the rights, safety and property of our customers, employees or company

Information may be shared with banks, payment providers, insurers, authorised agents, professional advisers, regulators, law-enforcement authorities or other competent bodies where permitted or required by law.

All information is handled in accordance with our Privacy Policy and applicable data-protection requirements.

16. Refusing or Cancelling a Transaction

Amigo Treks & Expedition may delay, reject, suspend or cancel a booking, payment, refund or business relationship when:

• Required information is not provided

• Submitted information appears false, altered or misleading

• The payer cannot be connected to the booking

• The source or purpose of funds cannot be reasonably understood

• A payment or refund instruction appears unusual or unlawful

• A sanctions or legal restriction may apply

• Processing the transaction could breach a law, licence condition or regulatory instruction

• Continuing the relationship would expose the company or its customers to unacceptable risk

Where legally permitted, we will provide the customer with general information about the documents or action required. We may be unable to disclose confidential compliance or reporting considerations.

17. Responsibilities of Our Team

All directors, employees and representatives of Amigo Treks & Expedition are responsible for following this policy.

Our team receives appropriate guidance on:

• Customer and payer verification

• Safe payment and refund handling

• Recognition of unusual transactions

• Internal escalation procedures

• Confidentiality and prohibition of tipping off

• Record keeping

• Compliance with applicable regulatory requirements

Detailed risk assessments, reporting procedures, internal escalation contacts and transaction-monitoring methods are maintained separately as confidential internal documents.

18. Customer Responsibilities

Customers and business partners are expected to:

• Provide accurate and complete information

• Use lawful payment sources and methods

• Ensure that the payer’s details are correctly stated

• Provide requested identification and supporting documents

• Inform us when a payment is being made by another person

• Avoid sending excess funds beyond the invoiced amount

• Use the original payment method for refunds wherever possible

• Inform us promptly if submitted information changes

Providing false documents or misleading information may result in rejection or cancellation of the transaction and may be reported where required by law.

19. No Assistance With Unlawful Transactions

Amigo Treks & Expedition will not knowingly assist any person to:

• Hide the source, ownership or destination of money

• Avoid lawful identification or reporting requirements

• Use a travel booking to transfer money to another person

• Process funds derived from unlawful activity

• Finance terrorism or prohibited organisations

• Evade sanctions, court orders, tax obligations or regulatory restrictions

• Obtain a false invoice, receipt, refund or booking confirmation

Employees and representatives are not authorised to make exceptions to this requirement.

20. Review of This Policy

Management will review this policy periodically and whenever there is a significant change in:

• Applicable laws or regulatory requirements

• Our foreign-exchange licence or permitted activities

• FIU-Nepal or Nepal Rastra Bank guidance

• Payment services used by the company

• Our products, destinations or customer profile

• Identified financial-crime risks

The latest version published on our website will apply from its stated effective date.

21. Contact Us

Questions regarding customer verification, payments or this policy may be directed to:

Amigo Treks & Expedition P. Ltd.
Thamel, Kathmandu, Nepal
Email: info@amigotrekking.com
Website: www.amigotrekking.com

For security and confidentiality reasons, Amigo Treks & Expedition does not discuss internal suspicious-transaction reviews or regulatory reports with customers or unauthorised persons.