AML and KYC/KYB Policy
AML and KYC/KYB Policy
AML and KYC/KYB Policy
Revised on April 19, 2025
XPayr is committed to preventing money laundering and terrorist financing. This policy outlines our Anti-Money Laundering (AML) and Know Your Customer/Know Your Business (KYC/KYB) procedures to ensure compliance with legal standards.
1. Purpose
XPayr adheres to strict AML and Counter-Terrorist Financing (CFT) standards to prevent the legalization of illicit funds. All employees must follow this policy to detect and report suspicious activities.
2. Definitions
- Money Laundering: Converting or concealing property derived from criminal activity to disguise its illegal origin.
- Terrorist Financing: Raising or allocating funds for terrorist acts or organizations.
- Politically Exposed Person (PEP): Individuals with prominent public functions, their family, or close associates.
- Ultimate Beneficial Owner (UBO): A person owning or controlling more than 25% of a legal entity.
- High-Risk Country: Jurisdictions identified by FATF or EU as having weak AML/CFT systems or significant criminal activity.
3. Customer Identification and Verification
- Individual Customers: XPayr may request full name, date of birth, email, residence, and payment wallet address. Verification requires proof of identity (e.g., passport) and residence (e.g., utility bill).
- Corporate Customers: XPayr may request legal name, incorporation date, email, and payment wallet address. Verification requires a certificate of incorporation and details of directors/UBOs.
- AML Letter: Financial service providers must submit an AML letter detailing their compliance measures.
4. Enhanced Due Diligence (EDD)
EDD is applied for high-risk cases, including:
- Doubts about data authenticity or UBO identification.
- PEPs or customers from high-risk countries.
- Unusual ownership structures or anonymous transactions.
Measures include additional document verification and source-of-funds checks.
5. International Sanctions
XPayr screens customers against sanctions lists (e.g., OFAC, UN, EU) to ensure compliance. Transactions with sanctioned entities or countries are prohibited.
6. Data and Record-Keeping
Customer data and transaction records are retained for at least 5 years after the business relationship ends, managed by the Compliance Officer.
7. Risk-Based Approach
Customers are assessed for risk (low, normal, high) based on behavior, PEP status, and country of origin. High-risk customers undergo enhanced monitoring.
8. Transaction Monitoring
XPayr monitors transactions for suspicious activity, researching customer profiles, fund sources, and counterparties. Findings are documented and reported if necessary.
9. Politically Exposed Persons (PEPs)
PEPs require management approval, source-of-funds verification, and ongoing monitoring. Customers are screened against PEP databases.
10. Reporting
Suspicious activities are reported to the Compliance Officer, who determines if a report to the Financial Intelligence Unit (FIU) is needed. Customers are not informed of reports.
11. Compliance Officer
The Compliance Officer oversees AML/CFT compliance, conducts training, reports to the FIU, and proposes policy updates.
12. Training
Employees receive regular AML/CFT training. New employees are trained within one week of joining.
13. FIU Requests
XPayr promptly provides documents and information upon FIU requests.
For inquiries, contact XPayr at [email protected].
