Anti-Money Laundering and Countering Financing of Terrorism Policy

Introduction

The Anti-Money Laundering and Countering Financing of Terrorism (hereinafter - the "AML/CFT Policy") of PlusPay Ltd. is designated to prevent and mitigate possible risks of PlusPay Ltd (hereinafter ‘the Platform’) being involved in any kind of illegal activity.
This policy refers to activities with respect to which measures have been adopted pursuant to relevant laws, relevant rules and regulations, for the purpose of preventing money laundering activities that a out by offenders through the Platform for the purpose of covering up and concealing the source and nature of the proceeds and profits that such offenders obtain through such crimes as those relating to narcotics, organized crimes, terrorism, smuggling, graft, bribery, financial fraud, breach of financial regulation and order.

Definitions

Anti-Money Laundering (AML) — the laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legal income. Despite the fact that AML laws cover a limited range of transactions and illicit conduct, their ramifications are extensive.
Counter the Financing of Terrorism (CFT)- government laws, regulations, and other practices designed to restrict access to funding and financial services for those designated as terrorists by the government.
Client Due Diligence (CDD) — measures and principles to identify and verify the identity of the client and the client's ultimate beneficial owner (UBO) and to gather data regarding the nature of the intended business relationship.
Enhanced Due Diligence (EDD) — additional enhanced client due diligence measures that must be applied where the client is a PEP or in any other situation which by its nature can present a higher risk of money laundering (ML) or terrorist financing (TF).
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) — Canada's financial intelligence government. Its mission is to facilitate the detection, prevention, and deterrence of ML/TF activities while protecting the personal data under its control.
Politically exposed persons (PEP) — according to Canada's regulations, PEPs can be subdivided into domestic and foreign politically exposed persons. A politically exposed domestic person is a person who, at a given time, holds or held within the time limit one of the offices or roles in or on behalf of the national government, a provincial government, or a municipality.
Risk-based approach (RBA) — it is a method for a company to conduct a risk assessment by analysing business, client, and/or business relationship elements to determine the impact of potential ML/TF risks and to implement controls and measures to mitigate these risks. RBA is an efficient method of combating ML/TF.
Suspicious activity — an activity, which arouses suspicions regarding ML/TF or an attempt to carry out such actions, or another associated criminal activity.
Suspicious Transaction Report (STR) — is a type of report that must be submitted to FINTRAC by the Company if there are reasonable grounds to suspect that a financial transaction that occurs or is attempted during business relationship is related to the commission or the attempted commission of an ML/TF offence.

Client Due Diligence (CDD) and Enhanced Due Diligence (EDD)

We diligently perform client due diligence as an integral component of our unwavering commitment to AML compliance. This process is comprehensively applied before establishing any business relationships with clients.
During the due diligence procedure, which includes Know Your Client (KYC) checks, we meticulously verify and cross-reference an individual's identity, the information they provide, and the documents they submit.
The Platform applies EDD measures in situations where there is higher-risk present in business relationships. The Company performs thorough client review and evaluates each client posing higher risk on a case-by-case basis.

Ongoing Due Diligence (ODD)

To ensure that the documents, data or information obtained during the onboarding of the client are appropriate and relevant, client due diligence must be exercised on an ongoing basis during the relationship, as part of regular monitoring of ML/TF risks or occasioned by the client undergoing significant changes.


Transaction Monitoring


The Company pays special attention to ongoing monitoring of transactions and client behavior to:

● Prevent all the possibilities of fraud and money laundering appearance;
● Report potential crime to relevant authorities;
● Mitigate financial crime.


We retain the right to request additional information or supporting documentation for any transaction.
Suspicious transactions and/or unusual patterns represent additional risk factors and increase client’s overall risk scoring.

Risk based approach (RBA)
The Platform employs a risk-based approach to combat and prevent money laundering and the financing of terrorism. To determine the appropriate level of anti-money laundering and counter-terrorism financing (AML/CFT) due diligence for each client, we create a compliance risk profile upon the commencement of our relationship.
The risk level is determined based on various factors, including information provided by users, their geographic location, the industries they are associated with, and whether users hold prominent public positions. It's important to note that the Platform retains the right to refuse the onboarding process for users, and such adjustments may be made without the need to provide a specific reason.
Once a business relationship is established with a user, we maintain a continuous focus on their identity and transaction history. If there are any changes or irregularities in this information or if we become suspicious of any data related to the user, we will promptly re-evaluate the user's identity and adjust their risk level categorization accordingly. Our aim is to ensure the ongoing integrity of our AML/CFT efforts and protect the Platform from potential risks.

Sanction Regime and Client Screening


The Platform's sanction regime meets regulatory requirements. The Platform checks clients, representatives, and UBOs against sanctions lists before doing business.Every active client is screened every 24 hours against sanctions lists.
Integral part of our onboarding process and ongoing due diligence is all clients screening against sanction, adverse media, PEP and enforcement lists.

AML Compliance Officer

The Compliance Officer's duties encompass the supervision of all facets of the Platform's anti-money laundering and counter-terrorist financing efforts, including, but not limited to:
● Establishing and updating internal policies and procedures for the completion, review, submission, and retention of all reports and records as required by applicable laws and regulations.
● Collecting and verifying clients' identification information, and implementing a records management system for the appropriate storage and retrieval of documents, files, forms, and logs.
● Gathering and analyzing information related to unusual transactions or circumstances suggestive of money laundering or terrorist financing, conducting investigations into any suspicious activity.
● Reporting suspicions of money laundering or terrorist financing to the relevant authorities and providing law enforcement with the necessary information in accordance with applicable laws and regulations.
● Organizing employee training initiatives.
● Fulfilling other duties and obligations related to compliance with legal requirements, and regularly updating risk assessments.
The Compliance Officer is authorized to collaborate with law enforcement agencies involved in the prevention of money laundering, terrorist financing, and other illicit activities.

Suspicious Activity Reporting



Should we come across any activity that raises suspicion of potential money laundering or terrorist financing, we are committed to promptly fulfilling our legal obligation by reporting it to the appropriate authorities.

In the event that a judicial or law enforcement authority from a country or region requests our assistance in connection with an investigation, the Platform reserves the right to collaborate and furnish the necessary information and materials as requested. This cooperation is carried out in accordance with the applicable legal requirements and authorities' requests


AML Training



We prioritize a comprehensive AML/CFT training program for all our employees, supplemented with job-specific guidance. This training is conducted on a minimum annual basis, ensuring that all participants stay well-informed and compliant with the latest laws and regulations. In addition, employees undergo supplementary training whenever the need arises, such as when new laws or regulations are enacted or as mandated by legal requirements.
Newly hired employees are also subject to pertinent training before they commence their roles within the organization. Our training program is subject to regular updates to align with the most current laws and regulations, ensuring our staff is consistently well-prepared to uphold compliance standards.


Record-Keeping



We maintain records of each client information and transactions as required by AML laws and regulations. This information is kept confidential and is only shared with authorized personnel and authorities when necessary.
We retain the originals or copies of the documents, which serve as the basis for identification and verification of persons, and the documents serving as the basis for the establishment of a business relationship no less than five years after termination of the business relationship.
We retain the documents prepared with regard to a transaction on any data medium and the documents and data serving as the basis for the notification obligations for no less than five years after making the transaction or performing the duty to report.


Conclusion

PlusPay Ltd. is dedicated to preventing money laundering and will take all necessary steps to ensure our AML program's effectiveness. We continuously update and enhance our AML program to adapt to changing regulations and emerging risks. We appreciate your cooperation in helping us maintain a safe and compliant environment.
Date of Last Update: 15.11.2023