AML POLICY

e-vPay Anti – Money Laundering & Counter – Terrorist Financing Policy

Last Update: June 11,2019

IPAY SERVICES LIMITED trading as e-vPay is a fully Authorized Payment Institution regulated by the Financial Conduct Authority FRN 824381, a competent authority under the Payments Services Directive that authorizes/registers payment institutions and enforces compliance with applicable conduct of business requirements.

e-vPay is also licensed and regulated under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) as an Annex I financial institution.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017, give the FCA responsibility for supervising the anti-money laundering controls of businesses that provide payment services.

As a global financial institution, e-vPay is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering (“AML”). The company fully supports the UK’s AML regime and has zero tolerance for criminal use, or misuse, of e-vPay’s services in furtherance of money laundering. We have robust policies and procedures in place, dedicated to prevent people engaged in money laundering, fraud, and other financial crimes, including terrorist financing, from using e-vPay’s services.

How does this impact me?

In compliance with the Money Laundering Regulations 2017 (MLR17), e-vPay takes reasonable and appropriate measures to establish identities of clients and others for who we may provide financial services to. e-vPay executes Know Your Customer (“KYC”) procedures on all clients. e-vPay may request additional information to help us identify you before we can provide our services.

Although the Company has separate account opening procedures that are followed when opening new accounts. These procedures must still be reviewed in conjunction with the Screening of Prospective Clients and Anti-Money Laundering Measures section of this website. However, in addition to those new account opening procedures, e-vPay must be familiar with our client’s identity. Below are factors to be considered in carrying out the “Know Your Client” duty.

Reasonable steps must be taken to check the client’s identity to show that they are who they claim to be and if applicable that they are trading for a legitimate business purpose. All new clients must provide sufficient information for verifying their identity before any advice is undertaken. e-vPay will obtain the following information from all prospective clients:

The KYC documents that you can provide is listed under the proof of identity and proof of address. This could either be done by scanning the document or by taking a high-resolution digital photograph.

Proof of identity document (with at least 3 months remaining)

  • • Driver's license (Front and back)
  • • Passport
  • • National Identity card (Front and back)
  • • Permanent resident or alien registration card (Front and back)
  • • Government-issued photo ID (Front and back)

Proof of address (issued within the last 3 months)

  • • Utility bill (Gas, Electricity, Water, Telephone) under your name.
  • • Bank Statement or credit card statement (No online/bank branch print-offs) under your name.
  • • Tax bill under your name.

Note:

  • • The copy should be clear enough to recognize your name, residential address, date of birth, and date of issue.
  • • Respective document can't be used for both proofs of identity and proof of address.
  • • All four edges should be clearly visible.

If the client does not provide required documentation within an acceptable time scale then we will discontinue any regulated activity and the matter should be brought to the attention of the MLRO. The MLRO will determine whether further action is required, under no circumstance must the client be informed of the decision to pass this to MLRO.

As part of our ongoing monitoring commitment, we may ask you for documentation should any details change on you or your business. e-vPay clients who present an elevated risk will have their client identification information updated at least every two years, or sooner depending on our evaluation. Clients who present an elevated risk includes (but is not limited to) Politically Exposed Persons (“PEPs”) in all of its legal forms. This is to be done by reviewing the original identity or entity document

You are independently responsible for complying with all applicable laws and all of your actions related to your use of e-vPay’s services, regardless of the purpose of the use. In addition, you must adhere to the terms of this Acceptable Use Policy.

How long is the due diligence documentation stored?

In order to enable us to comply with the Applicable Law, including but not limited to anti-terrorism, financial services, anti-tax evasion and anti-money laundering laws and regulations imposing Customer Due Diligence (“CDD”) requirements, as well as with the Payment Scheme’s and regulatory requirements is securely as per Regulation 40 of the Money Laundering Regulations 2017. Under Regulation 40 we must keep a copy of the documents and information obtained to fulfill our CDD obligations and sufficient supporting records of the transaction to enable it to be reconstructed for a period of five (5) years following the completion of the transaction or the end of the business relationship.

Prohibited Activities

You may not use the e-vPay’s service for activities that:

  • 1. Violate any law, statute, ordinance or regulation.
  • 2. Relate to transactions involving (a) narcotics, steroids, certain controlled substances or other products that present a risk to consumer safety, (b) drug paraphernalia, (c) cigarettes, (d) items that encourage, promote, facilitate or instruct others to engage in illegal activity, (e) stolen goods including digital and virtual goods, (f) the promotion of hate, violence, racial or other forms of intolerance that is discriminatory or the financial exploitation of a crime, (g) items that are considered obscene, (h) items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction, (i) certain sexually oriented materials or services, (j) ammunition, firearms, or certain firearm parts or accessories, or (k) certain weapons or knives regulated under applicable law.
  • 3. Relate to transactions that (a) show the personal information of third parties in violation of applicable law, (b) support pyramid or Ponzi schemes, matrix programs, other “get rich quick” schemes or certain multi-level marketing programs, (c) are associated with purchases of annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card, (d) are for the sale of certain items before the seller has control or possession of the item, (e) are by payment processors to collect payments on behalf of merchants, (f) are associated with the sale of traveler’s checks or money orders, (h) involve currency exchanges or check cashing businesses, (i) involve certain credit repair, debt settlement services, credit transactions or insurance activities, or (k) involve offering or receiving payments for the purpose of bribery or corruption.
  • 4. Involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent.

Overall, all activities, business arrangements or financial transactions which do not fit with the normal course of business should be assessed for money laundering or terrorist financing risk. Any transaction or arrangement where money laundering or terrorist financing is suspected must be dealt with expeditiously. Internal and External Suspicious Activity Reports (SARs) can be completed to highlight concerns and seek best guidance.