Anti-Money-Laundering & Counter-Terrorist-Financing Policy

ECardPay is committed to conducting its business in accordance with high standards of integrity and to combating money laundering, terrorist financing and the financing of proliferation. We work closely with our regulated Partners, who are responsible for the regulated activities they carry out, to ensure that appropriate financial-crime controls apply across the services.

We have no tolerance for the use of our services to launder the proceeds of crime, to finance terrorism, or to evade sanctions, and we take a firm approach to detecting and preventing such activity.

We operate a risk-based financial-crime programme designed to be consistent with the recommendations of the Financial Action Task Force (FATF) and with the anti-money-laundering and counter-terrorist-financing laws applicable to us and to the jurisdictions in which our Partners operate. A risk-based approach means we focus our controls where the risk of financial crime is highest.

Our programme includes governance and oversight, customer due diligence, sanctions and watchlist screening, ongoing transaction monitoring, suspicious-activity reporting, record keeping, and staff training, each described in outline below.

Before we make the full services available, and on an ongoing basis, we and our Partners carry out customer due diligence. For individuals this includes verifying identity using reliable, independent sources, with the support of verification providers. For businesses, we verify the entity and identify and verify its beneficial owners and controllers.

Where a customer, product or transaction presents a higher risk, for example because of the customer's profile, activity or jurisdiction, we apply enhanced due diligence, which may include obtaining additional information about the purpose of the relationship and the customer's source of funds or wealth, and obtaining senior approval to establish or continue the relationship.

We screen customers, and payments where appropriate, against applicable sanctions lists and other watchlists, and we screen for politically exposed persons (PEPs) so that any higher risk they present can be appropriately managed. We do not provide services to persons or entities that are subject to applicable sanctions, or to comprehensively sanctioned jurisdictions.

Where screening identifies a potential match or other concern, we may delay, block or decline a transaction, restrict or close an Account, and take any other action required to comply with our sanctions obligations.

We monitor activity across the services on an ongoing basis to identify transactions and behaviour that are unusual or inconsistent with what we know about a customer. Where activity warrants it, we may make a request for information (RFI), asking you to provide further details or documents, including evidence of your source of funds.

You agree to respond to such requests promptly and truthfully. While a request is being resolved, we may restrict activity on your Account. Failure to respond adequately may result in your Account being suspended or closed.

Where we or our Partners have knowledge or suspicion of money laundering, terrorist financing or other reportable activity, we are required to report it to the relevant authorities, such as a financial intelligence unit, in accordance with applicable law.

The law prohibits "tipping off" — that is, disclosing that a report has been made or that an investigation is being or may be carried out. For this reason, we may be unable to tell you the reason for certain actions we take, such as declining a transaction or restricting your Account.

We and our Partners keep records of customer due diligence, transactions and related financial-crime measures for the periods required by applicable law, typically at least five years after the end of the customer relationship or the completion of a transaction, and longer where required by a specific law, regulator or investigation.

We maintain a designated compliance function with responsibility for our financial-crime programme, with appropriate independence and access to senior management. Relevant staff receive training on financial-crime risks and on their obligations, including how to identify and escalate suspicious activity.

Our controls are subject to internal oversight and are reviewed and updated to reflect changes in risk, regulation and the services we offer.

As a condition of using the services, you agree to provide truthful, accurate and complete information, to respond promptly and honestly to requests for information, and to keep your details up to date. You must not use the services for money laundering, terrorist financing, sanctions evasion, fraud or any other unlawful purpose, as further described in our Terms of Service.

Breaching these obligations is a serious matter and may result in the suspension or closure of your Account and, where required, a report to the relevant authorities.

We cooperate with regulators, law-enforcement agencies and other competent authorities in accordance with applicable law, including by responding to lawful requests and orders. If you have questions about this Policy or wish to raise a financial-crime or compliance matter, contact us at hello@ecardpay.com.