ANTI MONEY LAUNDERING POLICY

1. Introduction
We are committed to preventing money laundering, fraud, and other financial crime. Although we are not a bank or regulated financial institution, we operate within the payment services sector and recognise the importance of maintaining high standards of due diligence, transparency, and ethical conduct. This policy outlines the measures we take to mitigate the risk of financial crime and ensure responsible business practices.

2. Our Commitment
We are committed to:

• conducting business with integrity
• taking reasonable steps to verify the identity of our clients
• identifying and assessing potential financial crime risks
• working only with reputable partners and service providers
• maintaining appropriate internal controls

3. Risk-Based Approach
We adopt a risk-based approach to anti-money laundering. This means we assess each client and business relationship based on factors such as:

• business activity and sector
• transaction volumes and patterns
• geographic location
• complexity of payment arrangements

Where higher risks are identified, enhanced due diligence may be applied.

4. Customer Due Diligence (CDD)
As part of our onboarding process, we may carry out checks to verify:

• identity of business owners or directors
• business legitimacy
• nature of the business activities
• expected payment volumes

We may request supporting documentation where appropriate.

5. Ongoing Monitoring
We may review business relationships periodically to ensure that:

• the nature of the business remains consistent
• there are no unusual or suspicious changes in activity
• our services are being used appropriately

6. Suspicious Activity
Where we identify activity that appears unusual or inconsistent with expected business operations, we reserve the right to:

• request further information
• pause or decline services
• report concerns to relevant authorities where appropriate

7. Third-Party Partners
We work with established payment providers and financial institutions who operate their own compliance and regulatory frameworks. We expect our partners to maintain appropriate anti-money laundering and financial crime controls.

8. Data and Record Keeping
We may retain records of due diligence and client interactions where necessary to:

• support compliance obligations
• demonstrate responsible business practices
• assist with any legal or regulatory enquiries

9. Training and Awareness
We maintain awareness of financial crime risks and aim to ensure that appropriate procedures are followed in our business operations.

10. Review of This Policy
This policy may be updated periodically to reflect changes in legislation, industry practices, or business operations.

11. Contact
If you have any questions regarding this policy, please contact us.