Anti-Money Laundering & Counter Terrorism Financing Policy 

Introduction 

MoiPayWay has a technology-driven company that offers services within the financial space, and it recognizes the need of preventing money laundering and terrorism financing. As a designated non-financial institution (DNFI), is subject to applicable legislation designed for the Prevention and Prohibition of Terrorism ( Act 2022), Money Laundering Prevention, and Prohibition (Act, 2022). For this purpose,

MoiPayWay has established policies and procedures for anyone that has business to do with MoiPayWay such as partners and employees must observe Customer Due Diligence MoiPayWay implement account opening processes and procedures that verify the identity of customers (partners, etc.) which are manual submission and automated, and as well as we run periodic checks on various checklists such as the Interpol. 

Assessment of Risk & Risk-Based Approach 

Based on the nature of the products and services MoiPayWay offers, each customer is placed on the category of risk involved in operating with our offerings, which helps in Identifying the potential risk, and will help to effectively manage these risks and implementing controls to mitigate the identified risk if they come. This is to ensure that anti-money laundering and counter-terrorist financing concerns are discovered and diminished.

MoiPayWay will not do business with persons or company that has been included in any official lists of sanctions, or involvement in criminal activities. Persons refusing to provide the required information or documentation; or Entities whose shareholder/control structure cannot be determined. 

Relationships with regulators and Law Enforcement Agencies 

MoiPayWay understands the risk and loss of being involved in money laundering and terrorist financing activities, with these MoiPayWay recognizes that complying with regulators and cooperating with law enforcement agencies is obligatory to maintain and fight against money laundering as it helps in a cooperative relationship with regulators and law enforcement agencies. MoiPayWay submits and also abides with requests made in accordance with regulators and Law Enforcement Agencies in need to counter terrorism and money laundering. Training in Anti-Money Laundering and Counter-Terrorism With a commitment to compliance, MoiPayWay makes its employees ( juniors and seniors) go through training to help conduct, and manage customer onboarding, management, and reporting of red flags of money laundering or terrorism financing that may occur in the course of their job duties. 

Reporting, Audit & Reviews 

To ensure we are complying and equally managing the transactions that are carried out using our product and solutions, we employ a periodic internal audit to ensure that the anti-money laundering and counter-terrorism financing mechanisms in place are effective. This provides the compliance department with the assurance and necessary information with respect to the operating processes and review of the policy. In an event of any suspicion or knowledge of possible Money Laundering activity employees and partners are mandated to report such activity to the compliance department of MoiPayWay by emailing (mailto:[email protected]) with information that includes at least; Identity of the suspected person or account, date of suspected activity and details of what was suspected with relevant reason. 

Retention of Records 

MoiPayWay keeps identification documents of customers for the period they use MoiPayWay products and services duration of the account and for at least five (5) years after the relationship ends. In the event of legal proceedings or regulatory exploration, records will be kept for the period of the inquiry.