Anti-Money Laundering (AML) Policy

1. Policy Statement

Paybis is committed to combating money laundering, terrorist financing, and other financial crimes. We have implemented robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) measures in compliance with international standards and local regulations.

2. Customer Due Diligence (CDD)

We implement a risk-based approach to customer due diligence, which includes:

• Collecting and verifying customer identification information (name, address, date of birth)
• Verifying the identity of beneficial owners for business accounts
• Understanding the nature and purpose of customer relationships
• Conducting ongoing monitoring of customer transactions
• Applying enhanced due diligence for high-risk customers

3. KYC Verification

All customers must complete Know Your Customer (KYC) verification before using our services. This includes:

• Providing government-issued identification documents
• Proof of address (utility bill, bank statement)
• Source of funds declaration when required
• Ongoing verification for certain transaction thresholds

4. Transaction Monitoring

We employ automated transaction monitoring systems to detect suspicious activities, including:

• Unusually large or frequent transactions
• Transactions with high-risk jurisdictions
• Structuring transactions to avoid reporting thresholds
• Rapid movement of funds between accounts
• Transactions involving known suspicious addresses

5. Suspicious Activity Reporting

When suspicious activity is detected, we:

• Conduct an internal investigation
• File Suspicious Activity Reports (SARs) with relevant authorities
• Freeze or restrict accounts when necessary
• Cooperate with law enforcement investigations
• Maintain records of all suspicious activity reports

6. Sanctions Screening

We screen all customers and transactions against global sanctions lists, including:

• OFAC (Office of Foreign Assets Control)
• UN Security Council Sanctions
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• Other relevant sanctions lists

7. Record Keeping

We maintain comprehensive records of:

• Customer identification and verification documents
• Transaction history for at least 5 years
• Suspicious activity reports and investigations
• AML training records for employees
• Risk assessments and policy updates

8. Employee Training

All employees receive regular training on:

• Current AML/CTF regulations and requirements
• Identifying red flags and suspicious activities
• Proper handling of customer verification
• Reporting procedures for suspicious activities
• Data protection and confidentiality requirements

9. Risk Assessment

We conduct regular risk assessments to identify and mitigate potential money laundering risks, considering:

• Customer geographic location and risk profile
• Product and service risk factors
• Delivery channel vulnerabilities
• Emerging threats and typologies

10. Compliance Officer

We have appointed a qualified AML Compliance Officer responsible for:

• Overseeing AML program implementation
• Receiving and reviewing suspicious activity reports
• Liaising with regulatory authorities
• Updating AML policies and procedures
• Conducting internal audits

11. Prohibited Activities

The following activities are strictly prohibited on our platform:

• Money laundering or terrorist financing
• Transactions involving illegal goods or services
• Using our platform for any unlawful purpose
• Attempting to bypass our AML controls
• Providing false or misleading information

12. Consequences of Non-Compliance

Violation of our AML policy may result in:

• Account suspension or termination
• Reporting to relevant authorities
• Asset freezing or seizure
• Legal prosecution
• Civil and criminal penalties