AML & KYC Policies and Procedures

The battle against money laundering (AML) and terrorist financing (CFT) is an ongoing and continous process. Since criminals require financial services in order to launder the proceeds of and fund their criminal activities, payment service providers must be able to identify and understand the potential risks of their services being used for money laundering and/or terrorist financing, and implement appropriate administrative processes to prevent, or at least minimize, such risks.

Proper Know-Your-Customer (KYC) practices are central. A strong knowledge of the customer provides a basis for understanding the general activities in which a customer usually would be expected to engage. This gives the payment service provider an opportunity to detect unusual and suspicious activities, investigate these appropriately, and alert relevant authorities when required.

In light of our changing environment, it is of great importance that payment service providers and other financial institutions continually evaluate the strength and relevance of their existing policies, procedures and employee training programs and, if necessary, update them to address these changes.

Money laundering and terrorism not only harm the public as a whole but can also damage the stability and reputation of the financial sector. It is obviously in society's best interests that all reasonable measures to prevent money laundering and terrorist financing are taken.

Our Anti-Money Laundering and Anti-Terrorist Financing Philosophy

It is of great importance that payment service providers act to combat the risks of money laundering and assist governments in the identification of potential terrorist funding activities. Below follow some of the things we do within Payssion:

• Payssion has adopted an Anti-Money Laundering and Anti-Terrorist Financing Policy that requires Payssion to develop and implement effective AML and CFT programs in compliance with applicable laws;
• Our Compliance Officer is responsible for developing and applying policies, practices and procedures to prevent money laundering and the financing of terrorist activities.
• We have established procedures and routines regarding Know-Your-Customer and Customer due diligence which, for example, comprise identifying the customer and verifying the customer's identity on the basis of documents, data or information obtained from a reliable and independent source (such as public records) and, where applicable, the beneficial owner.
• We have established implementation of appropriate controls, regulations and compliance procedures;
• Furthermore Payssion pays special attention;
• to understanding the ownership and control structure of our customers,
• to obtaining information on the purpose and intended nature of business relationship, and,
• to monitoring business relationships, including scrutiny of transactions to ensure consistency of transactions with obtained information about purpose and intended nature of business relationship;

If a customer's reasons for a transaction/activity are not clear or understandable Payssion takes measures in order to prevent money laundering or terrorist financing.

We rely on those closest to our customers - local branch managers, relationship managers and customer service personnel - to understand fully with whom we are doing business and to ensure that the business we conduct on behalf of our customers is legitimate;

• We have developed and continue to update policies and procedures that meet or exceed applicable legal and regulatory requirements, and continuously train employees in them;
• We have established processes, to assist governments in identifying relevant information with regard to suspected terrorist and money-laundering entities or individuals identified by government agencies (e.g. EU's and OFAC's sanction list).

Furthermore we fully co-operate with law enforcement and regulatory agencies to the extent that is possible in regard to applicable regulation.

• We have developed procedures that assist in the monotoring of transactions for the purpose of identifying possible suspicious activity;
• We recognise that preventing money laundering and identifying possible terrorist financing activities is an ongoing process that involves constant diligence and the ability to keep pace with the ever more sophisticated schemes employed by criminals;
• We have established employee training programs to educate and assist employees in the ways of preventing anti-money laundering and anti-terrorist financing transactions;
• Payssion does not allow direct use of correspondent accounts by third parties (payable through account) to transact business on their own behalf; and
• Payssion does not allow anonymous accounts.

Payssion continuously updates its policies and procedures, systems and technology, and we are training our staff to assure that we are well equipped to combat money laundering and other financial crimes and assist governments in the war on terrorism. All this is done in accordance with national legislation and international recognised standards and regulations. We are fully committed to remaining constantly alert to prevent the use of our products and services by those who would abuse them.