AML Policy

1. Policy Statement

Paebs Payments Ltd. ("Paebs") is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We comply with all applicable laws and regulations, including:

• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• UK Financial Conduct Authority (FCA) requirements
• Financial Action Task Force (FATF) recommendations

2. Risk-Based Approach

We adopt a risk-based approach to AML/CTF compliance, which means we assess and manage money laundering and terrorist financing risks based on:

• Customer Risk: Type of customer, business sector, and reputation
• Geographic Risk: Countries of operation and transaction flows
• Product/Service Risk: Types of services used and transaction patterns
• Channel Risk: How services are delivered and accessed

3. Customer Due Diligence (CDD)

We conduct customer due diligence on all customers before establishing a business relationship. This includes:

Standard Due Diligence

• Verifying the customer's identity using reliable, independent sources
• Identifying and verifying beneficial owners (for corporate customers)
• Understanding the nature and purpose of the business relationship
• Conducting ongoing monitoring of transactions

Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for higher-risk customers, including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Complex or unusually large transactions
• Customers with unclear ownership structures

4. Transaction Monitoring

We monitor transactions on an ongoing basis to detect suspicious activity. Our monitoring includes:

• Automated transaction monitoring systems
• Pattern analysis and anomaly detection
• Threshold-based alerts
• Manual review of flagged transactions

5. Suspicious Activity Reporting

When we identify suspicious activity, we report it to the National Crime Agency (NCA) through Suspicious Activity Reports (SARs). We maintain confidentiality regarding such reports as required by law.

6. Sanctions Screening

We screen all customers and transactions against relevant sanctions lists, including:

• UK HM Treasury consolidated list
• UN Security Council sanctions lists
• EU sanctions lists
• OFAC sanctions lists (for US-related transactions)

7. Record Keeping

We maintain records of:

• Customer identification and verification documents
• Transaction records
• Risk assessments
• Training records
• Internal and external reports

Records are retained for at least five years after the end of the business relationship or completion of a transaction.

8. Staff Training

All relevant staff receive regular AML/CTF training covering:

• Legal and regulatory requirements
• Company policies and procedures
• Recognizing suspicious activity
• Reporting obligations

9. Money Laundering Reporting Officer

We have appointed a Money Laundering Reporting Officer (MLRO) who is responsible for:

• Receiving and assessing internal suspicious activity reports
• Making external reports to the NCA
• Overseeing the AML/CTF compliance program
• Reporting to senior management and the board

10. Contact

For questions about our AML policy or to report concerns: