AML Policy

Introduction


  • Money laundering is the process by which illegally obtained money (from drug trafficking, terrorist activity or other serious crimes) is given the appearance of having originated from a legitimate source.
  • Financial institutions such as PayOp are at the forefront of the battle against this criminal activity, which uses the international financial system to transfer money around the Globe and disguise its true origin/place of income. The UK Government, alongside many other countries, has passed legislation designed to prevent money laundering and to combat terrorism.
  • This legislation forms the cornerstone of PayOp anti-money laundering (AML) obligations, policies and practices, which apply across our organisation worldwide.
  • Laws and regulations of PayOp in the Anti-Money Laundering Policy is designed to ensure that our organisation complies with the requirements and obligations set out in the UK legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of PayOp to be used as a facilitator financing crime.
  • The policy also covers counter terrorist financing issues in addition to AML. PayOp operations in different jurisdictions also comply with their local obligations, with the most rigorous standards taking priority.
  • PayOp as well follows the principles stated by the Wolfsberg group (http://www.wolfsbergprinciples.com).

Our AML Policy sets out the minimum standards applicable to our organisation worldwide, including:


  • The appointment of a Group Money Laundering Reporting Officer (GMLRO) and local Money Laundering Reporting Officers (MLROs), of sufficient seniority who have responsibility for oversight of central and local business compliance with relevant legislation, regulations, rules and industry guidance
  • Establishing and maintaining a risk based approach towards assessing and managing money laundering and terrorist financing risks
  • Establishing and maintaining risk based customer due diligence, identification, verification and “know your customer” procedures, including enhanced due diligence for those customers presenting higher risk
  • Screening of existing and prospective customers
  • Establishing and maintaining risk based systems and procedures to monitor customer accounts and activity
  • Procedures for reporting unusual activity internally and suspicious activity externally to the relevant law enforcement authorities
  • The maintenance of appropriate records
  • Regular training for all relevant employees to enable them to understand and fulfil their legal obligations and recognise the risk of the bank’s products and services being used to assist money laundering or terrorist financing
  • Establishing and maintaining appropriate communications, and monitoring conformance arrangements to ensure that Barclays policy requirements are understood and complied with in practice
  • The provision of appropriate management information and reporting to senior management around compliance with AML and Counter Terrorist Financing policy.

Prohibited transactions


  • It is strictly forbidden to send or receive payments as consideration for the sale or supply of: tobacco products, prescription drugs, drugs and drug paraphernalia, weapons (including without limitation, knives, guns, firearms or ammunition), satellite and cable TV descramblers, pornography, adult material, material which incites violence, hatred, racism or which is considered obscene, government IDs and licences including replicas and novelty items and any counterfeit products, unlicensed or illegal lotteries or gambling services (including without limitation the use of or participation in illegal gambling houses), unregistered charity services, items which encourage or facilitate illegal activities, prepaid debit cards or other stored value cards that are not associated with a particular merchant and are not limited to purchases of particular products or services, third party processing or payment aggregation products or services, multi-level marketing, pyramid selling or ponzi schemes, matrix programmes or other “get rich quick” schemes or high yield investment programmes, goods or services that infringe the intellectual property rights of a third party, un-coded/miscoded gaming, timeshares or property reservation payments (On and Off Plan). We reserve the right, in our sole discretion, to add categories of prohibited transactions by adding such categories either to these Terms of Use or an acceptable use policy published on the Website.
  • It is strictly forbidden to make payments to or to receive payments from persons or entities offering illegal gambling services, including (but not limited to) illegal sports betting, casino games and poker games. PayDo may suspend or terminate Client’s Account at any time or refuse to execute or reverse a transaction if PayDo believes that the Client directly or indirectly uses or have used his PayDo Account for or in connection with illegal gambling transactions. This list is not exhaustive and it is Client’s responsibility to ensure that he do not use PayDo’s services for transactions that may be considered illegal in Client’s jurisdiction.
  • The Client may not use our services if he is residing in certain countries. These countries will be listed on the Website and updated from time to time. This list is not exhaustive and we may in our sole discretion decide to discontinue or restrict our services in other countries at any time and without prior notice. We reserve the right to suspend or terminate the Client’s PayDo Account at any time if we reasonably believe to be required to do so by law or in order to comply with recommendations issued by a relevant government authority or recognised body for the prevention of financial crime.
  • The Client is strictly forbidden to use his PayDo Account for any illegal purposes including but not limited to fraud and money laundering. We will report any suspicious activity to the relevant law enforcement agency. The Client is prohibited from using his PayDo Account in an attempt to abuse, exploit or circumvent the usage restrictions imposed by a merchant on the services it provides.
  • The Client may only accept payments for certain categories of business after approval from us in our sole discretion. Such business categories include but are not limited to: money exchange or remittance businesses, including but not limited to bureaux de change, currency exchanges and purchase of travel money; the collection of any form of payments to charitable or not-for-profit organisations; dealing in natural resources such as jewels, precious metals or stones; live streaming; the sale or supply of alcoholic beverages; the sale of supply of dietary supplements and alternative health products; any other business category published in an acceptable use policy on the Website from time to time. In case the Client is in doubt whether his business falls under any of the above categories, the Client must contact Customer Service. We reserve the right in our sole discretion, to add business categories requiring approval by adding such categories either to these Terms of Use or an acceptable use policy published on the Website.
  • If the Client conducts or attempt to conduct any transaction in violation of the prohibitions contained in this section or without the necessary approval under section #5, we reserve the right to: reverse the transaction; and/or close or suspend the Client’s PayDo Account; and/or report the transaction to the relevant law enforcement agency; and/or claim damages from Client; and charge the Client an administration fee of up to 150 EUR if we apply any of the above.
  • It is Client’s and not our responsibility to ensure that the Client only sends payments to or receive payments from persons or entities for the sale or supply of goods and services that the Client may provide or receive in compliance with any applicable laws and regulations. The mere fact that a person or entity accepts payments through us is not an indication of the legality of the supply or provision of their goods and services. If the Client is in doubt as to the legality of a supply or purchase, he should not continue with his payment.