AML and KYC Policy
The PassimPay team (“PassimPay”, “Company”) is committed to maintaining the highest standards of integrity, transparency, and compliance with global regulations. The PassimPay team (“PassimPay”, “Company”) has no tolerance for money laundering, the financing of terrorism, or any other form of illicit activity, and is committed to implementing policies, procedures, and controls shaped by the best industry practices and the most effective anti-money laundering standards applied worldwide. We understand the importance of preventing money laundering and apply all the measures to prevent the use of our service for fraudulent or illegal purposes. This Anti-Money Laundering (AML) and Know Your Customer Policy outlines our dedication to combating financial crimes and ensuring the legitimacy of all transactions conducted through our platform.
These rules are universally applicable and extend to all individuals associated with the Company, including but not limited to its employees, Board members, partners, clients, contractors, etc.
1. Purpose of this Document
The purpose of this document is to offer a concise overview of the elements and procedures within the Company's Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) compliance regime. It is intended to provide insight to the Company's partners, clients, vendors, contractors, employees, regulators, law enforcement, and other stakeholders concerned with our AML/CTF efforts. Please note that this document is not an exhaustive representation of all the policies, procedures, and controls that the Company has implemented to prevent money laundering, financing of terrorism, and other illicit activities.
2. The Company defines money laundering as follows:
1. The act of converting or transferring property, with the knowledge that said property originates from criminal activity or active involvement in such unlawful actions, to conceal or disguise the illegal origin of the property. This may also include assisting any individual engaged in such activities to evade the legal consequences of their actions.
2. The act of concealing or disguising the genuine nature, source, location, disposition, movement, rights associated with, or ownership of property, with the knowledge that such property is derived from criminal activity or active involvement in such activity.
3. The act of acquiring, possessing, or utilizing property, with awareness at the time of receipt that the mentioned property was derived from criminal activity or active involvement in such activity.
4. Participation in, association with the intent to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the actions described in points 1, 2, and 3.
Terrorist financing involves the provision of funds for terrorist activities. Legally, it encompasses the act of acquiring or gathering funds, through any means, either directly or indirectly, with the intention that these funds will be used, or with the knowledge that they will be used, either in whole or in part, to facilitate any form of terrorism.
Terrorist activities primarily aim to intimidate a population or coerce a government into specific actions. This is achieved through deliberate acts such as intentional killing, causing severe harm or endangering individuals, inflicting significant property damage that has the potential to cause serious harm to people, or substantially interfering with or disrupting essential services, facilities, or systems.
Legal Framework
As a regulated business, PassimPay is required to comply with the Money Laundering and Terrorist Financing Prevention Act and International Sanctions Act, which require PassimPay to identify and verify its clients’ identities, conduct ongoing monitoring of their activity, including transaction monitoring, maintain records of clients’ activity and related documents for at least five years and report certain transactions to authorities.
PassimPay operates by applicable AML laws and regulations, including but not limited to the Financial Action Task Force (FATF) Recommendations, and relevant national and international legislation. Our compliance with these laws is non-negotiable.
3. Risk-Based Approach and Risk Assessment
At PassimPay, we employ a risk-based approach to our due diligence procedures, which includes gathering information and documentation for the assessment of each potential client's risk profile. Our dedicated team exercises diligence, good judgment, and utmost care to comprehensively evaluate the character and nature of all clients.
PassimPay is unwavering in its commitment to conducting business with the utmost adherence to the highest ethical standards. We are resolute in our decision not to engage in business relationships with individuals or entities that could potentially undermine our company's reputation or compromise the integrity of the virtual currency industry.
For identification, assessment, and analysis of risks of money laundering and terrorist financing related to its activities, the Company prepares a risk assessment, taking account of the following categories:
- Customer risk;
- Geographical risk;
- Product risk; and
- Delivery channel risk.
After the risk is assessed and attributed to a particular customer, depending on the degree of risk, it should be revised periodically upon knowledge of the customer and its activity.
Compliance Officer
The management board of the Company shall appoint a Compliance Officer, who performs AML/CTF duties and obligations of the Company and acts as a contact person of the FIU. A Compliance Officer reports directly to the management board and has the competence, means, and access to relevant information across all the structural units of the Company.
Only a person who has the education, professional suitability, abilities, personal qualities, experience, and impeccable reputation required for the performance of the duties listed below may be appointed as a Compliance Officer.
The duties of a Compliance Officer include, inter alia:
- organization of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the Company;
- reporting to the FIU in the event of suspicion of money laundering or terrorist financing;
- periodic submission of written statements on compliance with the requirements arising from the Act to the management board of the Company;
- performance of other duties and obligations related to compliance with the requirements of the Act.
4. AML Compliance Program
4.1. Due Diligence
The Company applies the following due diligence measures:
- identification of a customer and verification of the submitted information based on information obtained from a reliable and independent source, including using means of electronic identification and trust services for electronic transactions;
- identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer;
- understanding of business relationships, and, where relevant, gathering information thereon;
- verification of information on whether a person is a politically exposed person, their family member, or a person known to be a close associate;
- sanction screening of its customers;
- monitoring of a business relationship.
4.2. Transaction Monitoring
We employ sophisticated transaction monitoring systems to detect and report suspicious activities.
Customer's transaction pattern is monitored to detect unusual or suspicious transactions. PassimPay will therefore monitor all transactions and it reserves the right to request additional information from customers where transactions seem suspicious and report all suspicious transactions to the relevant authorities through its Compliance officer. PassimPay will make regular Suspicious transaction reports to the relevant authorities in cases they arise.
The compliance officer will carry out daily monitoring of all transactions to determine which transactions are legitimate and which seem suspicious. Suspicious/ Unusual transactions are reported to the relevant authorities.
4.3. AML Training
PassimPay ensures that all employees and stakeholders receive regular training on AML policies and procedures. This training helps maintain awareness and understanding of AML regulations and best practices.
The timing and content of the training provided is determined according to the needs of the Company. The frequency of the training can vary depending on to the amendments of legal and/or regulatory requirements, employees’ duties as well as any other changes in the business model. The training program aims to educate the Company’s employees on the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.
4.4. Record Keeping
PassimPay maintains comprehensive records of customer information, transactions, and AML-related documentation, no less than five years after termination of the business relationship.
The Company implements necessary rules for the protection of personal data upon application of the requirements arising from its obligations hereunder.
The Company is allowed to process personal data gathered upon implementation of these rules only for the purpose of preventing money laundering and terrorist financing and the data must not be additionally processed in a manner that does not meet the purpose, for instance, for marketing purposes.
5. Reporting and Compliance
5.1. Reporting Suspicious Activities
Where the Company identifies an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or other criminal offenses or an attempt thereof or with regard to which the Company suspects or knows that it constitutes money laundering or terrorist financing or the commission of another criminal offense, a Compliance Officer of the Company must report it to the FIU immediately after identifying the activity or facts or after getting the suspicion.
5.2. Compliance Reviews
PassimPay conducts regular internal AML compliance reviews to assess the effectiveness of our AML program and make necessary improvements.
6. KYC (Know Your Customer) Policy PassimPay
PassimPay is your reliable cryptocurrency processing service. Security and clarity in cooperation are our priorities. We do our best to ensure the transparency of our work and partnership. Therefore, to access PassimPay products and services, every user must read and agree with our KYC policy.
7. What is KYC?
KYC is the verification of a user, the confirmation of their identity by requesting personal data. It is the abbreviation for “Know Your Customer” or “Know Your Client”. KYC is a standardized procedure aimed at preventing illegal financial transactions, including money laundering and terrorist financing. It is a mandatory verification of a customer's identity.
Many users do not want to provide information about themselves, taking care of the security of confidential data. Still, it is worth remembering that online verification indicates the exchange’s reliability. The platform that does not require any data is not liable to you. If you visit a crypto exchange with no KYC required and hope to buy cryptocurrency without KYC, take responsibility for possible risks.
8. Who provides the KYC service?
Data processing and protection are handled entirely by our partner "AMLBot". AMLBot's identity verification platform is applicable worldwide, as its approach and methodology are carefully designed in accordance with the FATF recommendations for AML/CFT requirements, which serve as the international basis for local AML/CFT laws. The system is based on a risk-based approach and complies with global and local regulatory requirements. It is an industry-leading solution for securing KYC processes.
9. Required Documents for Verification
To complete the KYC process, you will be required to submit the following:
- A photo or a scanned copy of a passport or ID.
- Selfie with the document.
10. Verification Terms
Documents verification may take up to 2 working days from the date of submission.
11. Data Privacy
We strictly adhere to the principles of confidentiality. All data you provide will remain anonymous and will only be used within the framework of our security policy.
12. Consent to data processing
Verification of documents is carried out by our partner “AMLBot”. Your data is protected and will not be passed on to third parties.
By agreeing to our KYC policy, you consent to the processing of your personal data and verification of your identity by PassimPay Limited Liability Company, No: 3254, date of registration: 10/10/2023. This is necessary to ensure the security of your financial transactions and to comply with international laws.
13. Conclusion
PassimPay is fully committed to combating money laundering and terrorist financing. Our AML and KYC Policies reflect our dedication to maintaining the highest standards of integrity and regulatory compliance in all our operations.
We continuously monitor and adapt our AML measures to evolving risks and regulatory changes to ensure the safety and security of our platform and users.
By adhering to this AML and KYC Policy, PassimPay aims to contribute to a safer and more transparent financial ecosystem while providing our customers with reliable and compliant cryptocurrency payment gateway services.
This AML and KYC Policy is subject to periodic review and updates to ensure its effectiveness and alignment with the latest AML and KYC regulations. PassimPay reserves the right to modify this policy as required, and any such changes will be communicated through our official website.
For any inquiries or reports related to AML and KYC compliance, please contact us.