Compliance policy (KYC & AML)

The purpose of the Anti-Money Laundering and Know Your Customer Policy (“AML/KYC Policy”) is to prevent money laundering and terrorist financing activities on the Service by complying with international and domestic legal requirements and implementing user identification procedures.

According to the AML/KYC policy, the words "Paycard", "Company", "we", "us" or "our" refer to Paycard Service. Depending on the context, "Paycard" may also refer to the services , products, website, content or other materials provided.

The AML/KYC Policy is an integral part of the Terms of Use. By accepting the terms of use, you automatically agree to the AML / KYC policy. All terms specified in this AML/KYC Policy in capital letters and not otherwise defined have the same meanings as in the Terms of Use.


Capitalized terms in this Anti-Fraud Policy have the following meanings:

Prohibited Conduct means any illegal conduct, which includes fraud, corruption, money laundering, conspiracy, terrorist financing and any other criminal conduct.

Fraud means the use of deception for the purpose of pursuing personal interests and harming the interests of Users and / or Paycard.

Corruption means offering, giving, receiving or soliciting, directly or indirectly, anything of value that could unduly influence the actions of another party.

Money laundering means a scheme of financial transactions whose purpose is to conceal the identity, source and destination of illegally obtained money.

Collusion means an agreement between two or more parties to achieve an improper purpose, including unduly influencing the actions of another party.

Terrorist financing means the provision or collection of funds by any means, directly or indirectly, with the intention of their use or on the condition that they will be used in whole or in part for the commission of any of the crimes associated with terrorism.

Criminal conduct means a crime in any part of the world or something that would be classified as a crime in any part of the world if it occurred there.

All terms used in this Anti-Fraud Policy in capital letters and not otherwise defined have the same meanings as in the Terms of Use

1. General Provisions

1.1. The Company must comply with the requirements contained in the legislation and international laws on the prevention of money laundering and terrorist financing, as well as the requirements of other laws and regulations to the extent they are related to the Company's activities.

1.2. The company distributing the AML/KYC Policy may make changes and additions to it at its discretion and will monitor compliance with its provisions and requirements.

The current version of the Policy is always available on the website at:

2. Trade services department employee

2.1. To control and implement the procedures reflected in the Policy, the Company appoints a responsible person.

The responsible person is responsible for collecting, analyzing and investigating information about any suspicious activities and training company employees in appropriate procedures; The responsible person must define procedures and rules for identifying Customers, verifying and monitoring unusual transactions.

3. Identification policy

3.1. In order to identify Clients, the Company requests the following documents:

- Memorandum of association;

- certificate of state registration;

- charter of shareholders of the company;

- a document confirming the rights and powers of a person authorized to act on behalf of the company without a power of attorney, etc.;

- identification document (passport, driver’s license, ID card);

- confirmation of registration address (bank statement, utility bill);

- utility bill;

- letter of recommendation

3.2. The KYC (Know Your Customer) procedure applies to users suspected of committing illegal transactions. We may ask you for the following documents to prove your identity:

Identity documents:

- internal and/or foreign passport;

- identity card, ID card.

Address verification:

- a copy of the utility bill;

- telephone bill, electricity bill;

- Statement from the bank.

Other documents such as driver's license, etc.

4. Know Your Customer Verification Procedures

4.1. The Company carries out Know Your Customer (KYC) verification procedures to avoid the risk of liability and protect itself from the Client's attempts to use the Company to carry out illegal activities.

4.2. As part of the KYC procedures, the Company evaluates Clients' transactions, and also collects and stores information about material facts relating to Clients, potential Clients and their transactions.

4.3. After carrying out identification procedures relating to the Client, the Company stores the information received in the file of that Client. The Company is obliged to perform identification procedures related to the Client only once.

4.4. The Company strives to protect the rights of Clients and the confidentiality of their personal data. The Company collects personal information from Clients only to the extent necessary to ensure the proper provision of services by Clients. Such personal information about Clients and former Clients may be disclosed to third parties only in limited circumstances in accordance with applicable laws and agreements between the Company and the Client.

4.5. The Company shall carefully maintain the Client's files including statements, transaction reports, receipts, notes, internal correspondence and any other documents related to the Client in electronic format at all times in case they may be required by the underwriting teams at the respective banks- acquirers/processors used by the Client.

4.6. The Company has the right to suspend an Account associated with suspicious activity and ask the owner of such Account to undergo the KYC procedure.

5. Identify and detect suspicious activities

5.1. Any financial transaction that may be associated with money laundering is considered suspicious.

5.2. The basis for determining that a particular transaction is suspicious may be based on the personal observations and experience of Company employees, as well as information received or identified.

5.3. The Company's responsible person must continually monitor and update the systems used by the Company to detect suspicious activity.

5.4. In accordance with the current legislation and the requirements of international organizations, the Company may, where appropriate, and without the obligation to obtain approval or notification of the Client, notify regulatory and/or law enforcement authorities of any suspicious transactions.

5.5. The Company must periodically refer to lists published by the authorized bodies and international organizations, which contain the names of known terrorists or persons suspected of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subject to OFAC sanctions (Office of Foreign Assets Control), jurisdictions that do not provide sufficient anti-money laundering procedures, as well as countries subject to sanctions to determine whether the Company's Client or potential Client and/or the country of jurisdiction of such Client is included in the above lists.

5.6. The Company must continually conduct due diligence procedures with respect to its Clients and carefully review their transactions to ensure that those transactions are consistent with the Company's knowledge of its Clients, their business and, where appropriate, their source of income.

6. Amendments and modifications

6.1. This KYC Policy may be changed or supplemented at any time at the sole discretion of the Paycard. You acknowledge and agree that you are responsible for periodically reviewing the KYC Policy and becoming familiar with changes and additions.

6.2. If you do not want to accept the amended and/or supplemented KYC Policy, you should not continue to use this Service. Your continued use of the Site and/or Service after the publication of changes to the KYC Policy will be considered as your acceptance of these changes

7. Third parties

7.1. The Company may engage third party service providers to perform some of its business functions. The Company shall endeavor to determine, during the initial and ongoing process, to the extent possible, whether there are any pending investigations and claims against any such third party service providers. The Company must also determine whether the third party provider has obtained all necessary licenses, permits and approvals before entering into a business relationship with such third party service provider.

7.2. With respect to its own personnel, the Company must carefully review all applicants for employment and determine whether the new employee's activities fall into a category that is susceptible to money laundering. In addition, the Company has prepared and is implementing a number of personnel training programs in customer identification procedures and the prevention of money laundering.

8. User Agreement

8.1. By using our service, you warrant that you do not intend to engage in any of the prohibited activities described herein; In addition, you consent to any audits related to the conduct of an investigation under this Policy and agree to cooperate fully and promptly with the Fraud Officer in such investigation.

9. Declaration of Compliance

9.1. The Client acknowledges that they have read and understand the current Policy and that they (or their company) must act in full accordance with the requirements and standards set out in the Policy and comply with all applicable laws and other rules and requirements governing their activities as a Corporate Client .

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