PBC/KYC Policy

Introduction

PAYNEX’s anti-money laundering and know your customer policy (hereinafter referred to as the ‘PBC/KYC Policy’) has been developed with the aim of preventing and reducing the potential risks of PAYNEX becoming involved in any illegal activity.
Both international and local regulations require PAYNEX to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, and to take action in the event of any suspicious activity on the part of its users.
The PBC/KYC policy covers the following issues:

  • Verification procedures.
  • Compliance Officer.
  • Transaction tracking.
  • Risk assessment.

1. Verification procedures

One of the international standards for preventing illegal activities is customer due diligence (CDD). In accordance with CDD, PAYNEX establishes its own verification procedures within the framework of anti-money laundering and ‘Know Your Customer’ standards.

1.1. Identity verification

The PAYNEX identity verification procedure requires the User to provide PAYNEX with reliable and independent documents, data or information (e.g. national identity card, international passport, bank statement, utility bill). For these purposes, PAYNEX reserves the right to collect the User’s identification information for the purposes of the PBC/KYC Policy.
PAYNEX will take measures to verify the authenticity of the documents and information provided by Users. All legal methods will be used to verify identification information, and PAYNEX reserves the right to investigate certain Users who have been identified as risky or suspicious.
PAYNEX reserves the right to verify the identity of the User on an ongoing basis, especially in cases where their identification details have changed or their activity appears suspicious (unusual for that User). In addition, PAYNEX reserves the right to request updated documents from Users, even if they have undergone identity verification in the past.
User identification information will be collected, stored, transferred and protected in strict accordance with PAYNEX’s Privacy Policy and related regulations.
After verifying the User’s identity, PAYNEX may be exempt from potential legal liability in situations where its Services are used to carry out illegal activities.

1.2. Card verification

Users who intend to use payment cards in connection with PAYNEX Services must verify their cards in accordance with the instructions available on the PAYNEX Website.

2. Regulatory Compliance Officer

The Compliance Officer is a person duly authorised by PAYNEX whose responsibility is to ensure the effective implementation and compliance with the Anti-Money Laundering and KYC Policy. The Compliance Officer is responsible for overseeing all aspects of PAYNEX’s anti-money laundering and counter-terrorist financing activities, including, but not limited to:
a. Collecting user identification information
b. Establishing and updating internal policies and procedures for completing, verifying, submitting, and storing all reports and records required by applicable laws and regulations.
c. Monitoring transactions and investigating any significant deviations from normal activity
d. Implementing a records management system for the proper storage and retrieval of documents, files, forms, and records.
e. Regularly updating risk assessments
f. Providing law enforcement agencies with information required under applicable laws and regulations.
The compliance officer has the right to interact with law enforcement agencies involved in the prevention of money laundering, terrorist financing and other illegal activities.

3. Transaction monitoring

Users are identified not only by verifying their identity (who they are), but more importantly by analysing their transaction patterns (what they do). Thus, PAYNEX relies on data analysis as a tool for assessing risks and identifying suspicious activity. PAYNEX performs a range of compliance-related tasks, including data collection, filtering, record keeping, investigation management, and reporting. The system’s functionalities include:

  1. 1. Daily screening of users against recognised blacklists (e.g., OFAC), adding transfers across multiple data points, placing users on watch and denial lists, opening cases for investigation where necessary, sending internal messages, and completing legal reports where applicable;
  2. 2. Case and document management.
    In accordance with PBC/KYC policy, PAYNEX will monitor all transactions and reserves the right to:

    • -Ensure that suspicious transactions are reported to the appropriate law enforcement authorities through the compliance officer.
    • -Request additional information and documents from the user in case of suspicious transactions.
    • -Suspend or close a user’s account if PAYNEX has reasonable grounds to suspect that the user has been involved in illegal activities.

The above list is not exhaustive, and the compliance officer will monitor User transactions on a daily basis to determine whether such transactions should be reported and treated as suspicious or whether they should be treated as bona fide.

4. Risk assessment

PAYNEX, in accordance with international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By applying a risk-based approach, PAYNEX can ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the risks identified. This will allow for the most effective allocation of resources. The principle is that resources should be allocated according to priorities so that the greatest attention is paid to the greatest risks.