Anti-Money Laundering and CFT Policy.

The AML and CFT Policy of Paily aims to prevent risks of the platform being involved in illegal activities. This policy addresses measures adopted under relevant laws to prevent money laundering activities, covering crimes related to narcotics, organized crime, terrorism, smuggling, graft, bribery, financial fraud, and breaches of financial regulation.

Anti-Money Laundering (AML) — laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legal income.

Counter the Financing of Terrorism (CFT) — government laws and regulations designed to restrict funding access for designated terrorist entities.

Client Due Diligence (CDD) — measures to identify and verify client identity and ultimate beneficial owner, gathering business relationship data.

Enhanced Due Diligence (EDD) — additional verification measures applied when clients present higher money laundering or terrorist financing risks.

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) — Canada’s financial intelligence agency facilitating detection and prevention of ML and TF activities.

Politically Exposed Persons (PEP) — individuals holding significant government positions at national, provincial, or municipal levels.

Risk-Based Approach (RBA) — a method for a company to conduct a risk assessment by analysing business, client, and business relationship elements.

Suspicious Activity — activity raising concerns regarding ML or TF or associated criminal conduct.

Suspicious Transaction Report (STR) — reports submitted to FINTRAC when reasonable suspicion exists regarding transaction involvement in ML or TF offences.

Paily performs comprehensive client due diligence before establishing business relationships. This includes Know Your Client (KYC) checks verifying identity, information, and submitted documents. Enhanced due diligence measures apply where higher-risk relationships exist, with case-by-case client evaluation.

Client due diligence continues throughout the relationship to ensure onboarding documents remain appropriate and relevant, including regular ML and TF risk monitoring and review during significant client changes.

The company monitors transactions and client behavior to prevent fraud and money laundering, report potential crimes, and mitigate financial crime. Paily pays special attention to ongoing monitoring of transactions and client behavior.

The platform reserves the right to request additional information or documentation. Suspicious transactions and unusual patterns represent additional risk factors and increase the client’s overall risk scoring.

Paily employs RBA to combat money laundering and terrorism financing. Risk profiles are created based on user-provided information, geographic location, associated industries, and public positions. The platform may refuse onboarding without specific justification.

Continuous focus is maintained on client identity and transaction history. Risk level adjustments occur promptly upon detecting irregularities or suspicions.

Paily’s sanctions regime meets regulatory requirements. Clients, representatives, and ultimate beneficial owners are screened against sanctions lists before business commencement. Active clients undergo screening every 24 hours against sanctions, adverse media, PEP, and enforcement lists.

The Compliance Officer supervises all AML and CFT efforts, including:

• Establishing and updating internal policies and procedures.
• Collecting and verifying client identification information.
• Gathering and analyzing unusual transaction information.
• Reporting suspicions to relevant authorities.
• Organizing employee training.
• Regularly updating risk assessments.

The officer is authorized to collaborate with law enforcement agencies.

Upon discovering suspicious activity, Paily fulfills legal obligations by reporting to appropriate authorities. The platform cooperates with judicial and law enforcement requests, furnishing necessary information per applicable legal requirements.

Comprehensive AML and CFT training occurs annually for all employees, supplemented by job-specific guidance. New employees receive pertinent training before commencing roles. Our training program is subject to regular updates to align with the most current laws and regulations.

Client information and transaction records are maintained confidentially, shared only with authorized personnel and authorities when necessary. Original or copy documents serving as identification and business relationship basis are retained no less than five years after termination of the business relationship.

Transaction documents and reporting documentation are retained no less than five years after making the transaction or performing the duty to report.

Paily remains dedicated to preventing money laundering through continuous program updates addressing regulatory changes and emerging risks.