Anti-Money Laundering Policy

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1. Introduction

Paynetik is committed to the highest standards of anti-money laundering (AML) compliance and counter-terrorist financing (CTF). This policy outlines our commitment to preventing the use of our services for money laundering or any activity that facilitates money laundering, terrorist financing, or other criminal activities.

2. Scope

This AML policy applies to all employees, officers, directors, and agents of Paynetik, as well as to all customers and users of Paynetik services. It covers all transactions and activities conducted through our platform.

3. Legal and Regulatory Framework

Paynetik operates in compliance with all applicable AML and CTF laws and regulations. This includes adherence to the guidelines set forth by relevant authorities and international bodies, such as the Financial Action Task Force (FATF).

4. Responsibilities

4.1 Management: Paynetik’s management is responsible for establishing and maintaining an effective AML program. This includes providing the necessary resources and support to ensure compliance with this policy and relevant laws.

4.2 Compliance Officer: A designated AML Compliance Officer is responsible for overseeing the implementation and operation of the AML program. The Compliance Officer's duties include monitoring transactions, reporting suspicious activities, and ensuring that employees are adequately trained in AML procedures.

4.3 Employees: All employees are required to be familiar with and comply with this AML policy. Employees must report any suspicious activity to the Compliance Officer promptly.

5. Customer Due Diligence (CDD)

5.1 Know Your Customer (KYC): Paynetik implements a rigorous KYC process to verify the identity of our customers. This includes collecting and verifying personal information such as name, address, date of birth, and identification documents.

5.2 Enhanced Due Diligence (EDD): For higher-risk customers, including politically exposed persons (PEPs) and customers from high-risk jurisdictions, Paynetik conducts enhanced due diligence. This involves additional scrutiny and verification of the customer’s identity and source of funds.

6. Monitoring and Reporting

6.1 Transaction Monitoring: Paynetik employs advanced monitoring systems to detect and flag suspicious transactions. Our systems analyze transaction patterns and behaviors to identify potential money laundering activities.

6.2 Suspicious Activity Reporting (SAR): If a transaction or customer activity is deemed suspicious, it will be reported to the appropriate authorities in accordance with applicable laws and regulations. Employees are required to report any suspicious activity to the Compliance Officer immediately.

7. Record Keeping

Paynetik maintains detailed records of all transactions and customer information in compliance with legal requirements. These records are kept for a minimum of five years and are available for review by regulatory authorities upon request.

8. Training and Awareness

Paynetik provides regular AML training to all employees. This training includes information on identifying suspicious activities, understanding AML laws and regulations, and following internal reporting procedures. Employees are required to complete AML training annually.

9. Risk Assessment

Paynetik conducts regular risk assessments to identify and mitigate potential AML risks. These assessments evaluate customer risk, transaction risk, and geographic risk to ensure that our AML program remains effective and up-to-date.

10. Policy Review

This AML policy is reviewed and updated regularly to reflect changes in laws, regulations, and industry best practices. The Compliance Officer is responsible for ensuring that the policy is current and effective.

11. Consequences of Non-Compliance

Failure to comply with this AML policy may result in disciplinary action, including termination of employment or business relationships. Additionally, individuals or entities that engage in money laundering or terrorist financing may face legal consequences, including prosecution and penalties.