1. Introduction
    1. Paybender is committed to preventing money laundering and the financing of terrorism by complying with all applicable anti-money laundering (AML) laws and regulations.
    2. This Anti-Money Laundering Policy outlines our commitment to detecting and preventing money laundering activities on our platform.
  2. Compliance Responsibilities
    1. Paybender’s management team is responsible for ensuring compliance with AML laws and regulations.
    2. All employees are required to complete AML training and to report any suspicious activities or transactions to the designated compliance officer.
  3. Customer Due Diligence
    1. Paybender conducts customer due diligence (CDD) on all customers to verify their identity and assess their risk level.
    2. CDD includes verifying the customer’s identity through government-issued identification documents and obtaining additional information as necessary.
    3. Enhanced due diligence (EDD) is conducted for high-risk customers, including ongoing monitoring of their transactions and activities.
  4. Transaction Monitoring
    1. Paybender monitors all transactions on its platform for unusual or suspicious activity that may indicate money laundering or terrorist financing.
    2. Transactions that are flagged as suspicious are escalated to the compliance team for further investigation.
  5. Reporting Requirements
    1. Paybender complies with all reporting requirements under AML laws and regulations, including filing suspicious activity reports (SARs) with the appropriate authorities.
    2. Employees are required to promptly report any suspicious activities or transactions to the designated compliance officer.
  6. Record Keeping
    1. Paybender maintains accurate and up-to-date records of all customer transactions and due diligence efforts in accordance with AML laws and regulations.
    2. Records are retained for the required period as specified by applicable laws and regulations.
  7. Training and Awareness
    1. Paybender provides regular training and awareness programs to employees to ensure they understand their responsibilities under this AML Policy.
    2. Employees receive training on recognizing and reporting suspicious activities, as well as the consequences of non-compliance with AML laws and regulations.
  8. Conclusion
    1. Paybender is committed to maintaining a robust AML program to prevent money laundering and terrorist financing activities on its platform.
    2. This AML Policy is reviewed regularly and updated as necessary to ensure compliance with evolving laws and regulations.