Anti-Money Laundering (AML)

We take action against money laundering and terrorist financing

The battle against money laundering (AML) and counter financing of terrorism (CFT) is an ongoing and continuous process.

Since criminals require financial services in order to launder off proceeds and fund their criminal activities, payment service providers must be able to identify and understand the potential risks of their services being used for money laundering and/or terrorist financing. They must also be able to implement appropriate administrative processes to prevent, or at least minimize, such risks.

Proper Know Your Customer (KYC) practices are central. A strong knowledge of the customer provides a basis for understanding the general activities in which a customer would usually be expected to engage. This gives the payment service provider an opportunity to detect unusual and suspicious activities, investigate these appropriately, and alert relevant authorities when required. In light of our changing environment, it is of great importance that payment service providers and other financial institutions continually evaluate the strength and relevance of their existing policies, procedures and employee training programs and, if necessary, update these to reflect these changes.

Money laundering and terrorism not only harm the public as a whole but can also damage the stability and reputation of the financial sector. It is in society's best interest that all reasonable measures be taken to prevent money laundering and terrorist financing. It is of great importance that payment service providers act to combat the risks of money laundering and assist governments in the identification of potential terrorist funding activities.

Payment21® follows the Policies and Procedures outlined hereafter:

Payment21® has adopted an Anti-Money Laundering and Anti-Terrorist Financing Policy that require us to execute effective AML and CFT programs in compliance with applicable laws. Our Compliance Officer is responsible for developing and applying policies, practices and procedures to prevent money laundering and the financing of terrorist activities. We have established employee training programs to educate and assist employees in fraud prevention, anti-money laundering and anti-terrorist financing.

1. We have established procedures and routines regarding Know-Your-Customer and Customer due diligence.

For example, our established procedures and routines comprise identifying the client and verifying the client's identity on the basis of documents, data or information obtained from a reliable and independent source (such as public records) and, where applicable, the beneficial owner.

2. We have implemented appropriate controls, regulations and compliance procedures.

Furthermore, Payment21® pays special attention to understanding our client's' ownership and control structure, obtaining information on the purpose and intended nature of a business relationship, and monitoring business relationships, including scrutinizing transactions to ensure consistency with information obtained about the purpose and intended nature of a business relationship. If a customer's reasons for a transaction/activity are not clear or understandable, Payment21® takes measures in order to prevent money laundering or terrorist financing.

3. We rely on those closest to our clients.

Namely Internet payments managers, accounting staff, operations managers, and customer service personnel - to understand fully with whom we are doing business and to ensure that the business we conduct on behalf of our clients is legitimate. We have developed, and update on an ongoing basis, policies and procedures that meet or exceed applicable legal and regulatory requirements, and continuously train employees in these.

4. We fully cooperate with law enforcement and regulatory agencies to the extent possible with regard to applicable regulation.

We have established processes to assist governments in identifying relevant information with regard to suspected terrorist and money-laundering entities or individuals identified by government agencies (e.g. EU and OFAC sanction lists).

5. We have developed procedures to assist in the monitoring of transactions for the purpose of identifying possible suspicious activity.

Payment21® does not allow direct use of correspondent accounts by third parties (payable through account) to transact business on their own behalf and Payment21® does not allow anonymous accounts. We recognize that preventing money laundering and identifying possible terrorist financing activities is an ongoing process which requires constant due diligence and the ability to keep pace with the ever-more sophisticated schemes employed by criminals.

6. Payment21® updates its policies and procedures, systems and technology on an ongoing basis.

We train our staff to assure that we are well equipped to combat money laundering and other financial crimes and assist governments in the war on terrorism. All this is carried out in accordance with national legislation and international recognized standards and regulations. We are fully committed to remaining constantly alert to prevent the use of our products and services by those who may abuse them.

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