ANTI-MONEY LAUNDERING AND COUNTER FINANCING TERRORISM POLICY
PAYMIQ FINANCIAL GROUP LTD
I. INTRODUCTION
PAYMIQ FINANCIAL GROUP LTD is a Financial Services Provider that provides support to client worldwide to execute payment transactions, including transfers of funds on a payment account with the payment service provider of the payment service user or with another payment service provider: execution of Money Remittance, direct debits, including one-off direct debits, execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders. PAYMIQ FINANCIAL GROUP LTD maintains compliance with the regulation of FINTRAC as well as other related authorities. PAYMIQ FINANCIAL GROUP LTD is committed to the highest standards in effort to comply with the applicable Anti Money Laundering and Counter Financing Terrorism (AML-CFT) standards. The Policy provides an introduction to anti money laundering and counter financing terrorism regulation.
The Management (BOD) and all employees are required to adhere the standards to protect PAYMIQ FINANCIAL GROUP LTD and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.
Government has enacted laws and rules designed to implement the anti-money laundering and counter financing terrorism. The goal of these laws is to detect and to prevent money laundering as well as potential terrorist financing. PAYMIQ FINANCIAL GROUP LTD will adhere to applicable laws and regulations in Canada.
PAYMIQ FINANCIAL GROUP LTD will verify its AML – CFT framework, goals and strategies on a periodical basis and maintain an effective program for the business that reflects the best practices for financial institution in general.
II. STRUCTURE AND POLICY
PAYMIQ FINANCIAL GROUP LTD has active Supervisory Board under Compliance Officer, and the implementation of AML – CFT Program handled by AML – CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to applicable AML – CFT Program derived from AML-CTF procedure.
PAYMIQ FINANCIAL GROUP LTD has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML – CFT regulations.
The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:
- Active supervision of the Board of Directors
- Policies and Procedures;
- Internal Control;
- Information Management System; and
- Human Resources and Training
III. CUSTOMER DUE DILIGENCE
PAYMIQ FINANCIAL GROUP LTD has implemented know your customer (KYC) procedure to assure all kinds of customers are subject to identification and verification process. The KYC has been implemented in all branches and business units. The goals are PAYMIQ FINANCIAL GROUP LTD has sufficient information and data about the customers profile, whom they deals with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and customers from high risk businesses or countries, name screening, and the ongoing monitoring and updating data of all existing customers.
PAYMIQ FINANCIAL GROUP LTD shall refuse to support or has to close an existing clients, if the following:
- Cannot fix a reasonable belief that it knows the true identity of the customer and/or UBOs and/or the nature of business concerning the identification of the customers are not met;
- Known and/or suspected the utilization of fake documents;
- Assets that are known or suspected to be the proceeds of criminal activity;
- Enter into business relationships with individuals or entities known or suspected to be a terrorist or a criminal organization or listed on sanction lists;
- Maintain anonymous accounts or accounts operate for shell banks.
IV. REGULATORY REPORTING
PAYMIQ FINANCIAL GROUP LTD has an obligation to report cash transaction with certain amount based on relevant regulation, suspicious transaction/activity, and international fund transfer. Suspicious transactions must be handled and escalated with approval of Compliance Officer prior reporting to regulator.
V. AML – CFT ENTITY RISK ASSESSMENT
The AML-CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML-CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on customer, country or geographical factors, products, services, transactions or distribution channels (delivery channels).
VI. SANCTIONS COMPLIANCE
Sanctions Compliance Implementation is important in PAYMIQ FINANCIAL GROUP LTD activities. PAYMIQ FINANCIAL GROUP LTD obligates to establish restrictions and controls on the movement of goods, services, and customers’ funds were transacted through the products and services that provided by PAYMIQ FINANCIAL GROUP LTD. Sanctions Compliance implementation goal is to keep PAYMIQ FINANCIAL GROUP LTD from compliance risk, operational risk and reputational risk exposure. PAYMIQ FINANCIAL GROUP LTD implements AML-CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation based on PAYMIQ FINANCIAL GROUP LTD and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.
VII. RECORD RETENTION
PAYMIQ FINANCIAL GROUP LTD has to record all data and or information regarding customer’s documents, client’s companies and/or its financial transactions (if any). PAYMIQ FINANCIAL GROUP LTD maintains customers documentations for minimum of 5 (five) years, notwithstanding to longer retention as required. PAYMIQ FINANCIAL GROUP LTD will provide information and/or documents competent authorities as ordered by laws and regulations, when required.
VIII. TRAINING
PAYMIQ FINANCIAL GROUP LTD has implemented AML – CFT training program for all staff. PAYMIQ FINANCIAL GROUP LTD’s training program is tailored to the operations and business unit to assure all staffs are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML – CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.
IX. INTERNAL CONTROL
PAYMIQ FINANCIAL GROUP LTD has an effective internal control system. PAYMIQ FINANCIAL GROUP LTD AML – CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML – CFT Program.
This Policy is an integral part of our Anti-Money Laundering and Counter Financing Terrorism Procedure and shall take effect from September 22, 2021.
Download the app
PAYMIQ FINANCIAL GROUP LTD is a company registered in Canada, registered number: BC1306026, registered address: DataTech Business Centre, 1095 McKenzie Ave Suite 300, Victoria, British Columbia, V8P 2L5, Canada. Email info@paymiq.com PAYMIQ FINANCIAL GROUP LTD is regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (Reg. No. M21430455).
©2022 by PAYMIQ. All rights reserved