AML/KYC/CTF Policy

1. Purpose and scope

1.1 Payowire is committed to preventing the use of its Platform for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, bribery, corruption, tax evasion and other financial crime.

1.2 This AML Policy applies to all users (personal and business), all products (receiving accounts, transfers, withdrawals, cards, adding funds, airtime and referrals), and to our employees, contractors and agents. Our licensed Partners apply their own AML programmes in addition to ours, and you must satisfy both.

2. Regulatory framework

2.1 Our controls are designed with reference to internationally recognised standards and the laws that apply to us and our Partners, including:

• the Recommendations of the Financial Action Task Force (FATF);
• applicable anti-money laundering and counter-terrorist financing laws and regulations in the countries where we and our Partners operate;
• economic and trade sanctions programmes administered by, among others, the United Nations Security Council, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the European Union and the United Kingdom (HM Treasury / OFSI); and
• card network rules and the compliance requirements of our banking, card-issuing and payment Partners.

2.2 References to these frameworks describe the standards our programme follows. They are not a statement that Payowire itself holds any particular licence or registration. Regulated services are provided by or through licensed Partners, as described in our Terms of Service.

3. Risk-based approach

3.1 We apply a risk-based approach. We assess the money laundering and terrorist financing risk of each customer and relationship using factors such as country of residence and nationality, business type and industry, products used, expected and actual transaction volumes, sources of incoming funds, delivery channels and adverse information.

3.2 Customers are assigned a risk rating that determines the depth of due diligence, monitoring and limits applied. Ratings are reviewed periodically and whenever we become aware of a relevant change.

4. Customer identification and due diligence (KYC/CDD)

4.1 Before giving access to all or part of the Services, and at any time afterwards, we will identify and verify you. For individuals this typically includes:

• full legal name, date of birth, nationality and residential address;
• a valid government-issued photo identity document (such as a passport, national identity card or driving licence);
• a live selfie or video check to confirm that you are the person in the document;
• proof of address dated within the last three months, where requested; and
• information about your occupation, the purpose of your account and the expected nature and volume of activity.

4.2 We may use automated identity verification, document authenticity checks, liveness checks and database checks provided by specialist third parties.

4.3 Until verification is complete, accounts may be unavailable or subject to reduced limits. We will not open or maintain anonymous accounts or accounts in obviously fictitious names.

4.4 Ongoing due diligence. We keep customer information up to date and may ask you to re-verify your identity or provide updated documents at any time, including on a periodic basis according to your risk rating.

5. Enhanced due diligence (EDD) and PEPs

5.1 We apply enhanced due diligence where the risk is higher, for example where a customer:

• is a politically exposed person (PEP), a family member or close associate of a PEP;
• is connected with a high-risk jurisdiction identified by FATF or by us;
• operates in a higher-risk industry, or uses complex or unusual ownership structures;
• conducts unusually large, complex or frequent transactions, or activity that does not fit their profile; or
• is the subject of adverse media or law enforcement interest.

5.2 EDD may include source-of-funds and source-of-wealth evidence (such as payslips, tax returns, bank statements, invoices, contracts or sale documents), additional identity checks, senior management approval and more frequent reviews.

6. Business accounts: KYB and beneficial ownership

6.1 For Business Accounts we verify the business and the people behind it. We may request:

• certificate of incorporation or registration, constitutional documents, and proof of registered and trading address;
• details of directors, partners, authorised signatories and anyone with authority to operate the account, with identity verification for each;
• the identity of every ultimate beneficial owner (UBO) who directly or indirectly owns or controls 25% or more of the business (or a lower threshold where required by law or our risk assessment), and of any person who otherwise exercises control;
• an ownership structure chart for multi-layered structures;
• a description of the business, its website, products, customers, suppliers and countries of operation; and
• any licences or registrations needed to carry on the business lawfully.

6.2 You must tell us promptly about any change in ownership, control, directors, activity or address.

7. Sanctions screening

7.1 We screen customers, beneficial owners, authorised persons and, where relevant, counterparties against applicable sanctions lists (including UN, OFAC, EU and UK lists), PEP lists and adverse media at onboarding and on an ongoing basis.

7.2 We do not provide services to sanctioned persons, entities owned or controlled by them, or for activity involving comprehensively sanctioned countries or regions. Transactions that may involve sanctioned parties will be blocked or rejected, and funds may be frozen and reported as required by law.

8. Transaction monitoring

8.1 We monitor transactions and account activity using automated systems and manual review to detect unusual or suspicious patterns, such as structuring to avoid limits, rapid movement of funds in and out, activity inconsistent with your profile, third-party funding, payments linked to high-risk countries, and indicators of fraud, scams or money mule activity.

8.2 When alerts are generated, we may contact you for information about a transaction, its purpose, the relationship with the counterparty, or the source of funds. Transactions may be held while we review them.

9. Suspicious activity reporting

9.1 Where we or our Partners know, suspect or have reasonable grounds to suspect that activity involves the proceeds of crime, terrorist financing or another reportable matter, we will report it to the competent financial intelligence unit, regulator or law enforcement authority, as required or permitted by law.

9.2 We may take such action without notice to you and without your consent.

10. Prohibited jurisdictions and activities

10.1 We do not accept customers resident in, or transactions involving, countries and regions that are subject to comprehensive sanctions, or that are identified by FATF as high-risk jurisdictions subject to a call for action, or that are otherwise unsupported by us or our Partners. The list of supported countries may change at any time.

10.2 Prohibited activities include those listed in our Acceptable Use Policy, such as money laundering, terrorist financing, fraud and scams, acting as a money mule, unlicensed money transmission, illegal gambling, illegal drugs and weapons, and any activity designed to evade sanctions, tax, reporting thresholds or our controls.

11. Record keeping

11.1 We keep customer due diligence records, identity documents, transaction records, correspondence and records of our monitoring and reporting for at least five (5) years after the end of the business relationship or the date of the transaction, or longer where required by law, a regulator, a Partner or an ongoing investigation. This retention applies even if you close your account or ask us to delete your data.

12. Our rights: refusal, holds, freezing and termination

12.1 To comply with this AML Policy and applicable law, we may at any time, at our discretion and without liability:

• refuse to open an account or to provide a particular Service;
• request additional information or documents, and restrict the account until they are provided;
• delay, hold, reject or return any transaction;
• freeze or block funds, accounts and cards;
• reduce limits or withdraw features;
• close the account and end the relationship; and
• share information with Partners, regulators and law enforcement.

12.2 Where funds are frozen because of a legal requirement or a suspicion of financial crime, they may remain frozen until we are legally permitted and satisfied to release them, or may be returned to their source or surrendered to authorities as required by law.

13. No tipping-off

13.1 We may be prohibited by law from telling you that we have made a report, that an investigation is under way, or the reason for a hold, freeze or closure. In those cases we will not be able to give you an explanation, and you agree that we are not liable for not doing so.

14. Governance and staff training

14.1 Our AML programme is overseen by a designated compliance function. Employees and contractors in relevant roles receive AML, sanctions and fraud training at onboarding and regularly afterwards, and our controls are reviewed periodically to remain effective.

15. Your obligations

15.1 By using Payowire you agree to:

• provide true, accurate, complete and up-to-date information and documents;
• respond promptly and fully to our requests for information (normally within the deadline we give you);
• use your account only for yourself or the business you represent, and never for third parties;
• only use funds from lawful sources that belong to you;
• not split, structure or route transactions to avoid limits, reporting or checks; and
• tell us immediately if you suspect your account is being misused.

15.2 Failure to cooperate may result in restrictions, delays, or closure of your account.

16. Reporting concerns

16.1 If you believe a Payowire account is being used for financial crime, or you have been asked to receive or move money for someone else, contact support@payowire.com. Reports are treated confidentially.

17. Updates to this policy

17.1 We review this AML Policy regularly and may update it at any time to reflect changes in law, regulatory guidance, Partner requirements or our risk assessment. The current version is always published on this page with its "Last updated" date.