This policy aims to prevent and identify any activities related to money laundering or terrorist financing. PayVert upholds a strict zero-tolerance stance against money laundering, terrorist activities, and related financial crimes. Furthermore, PayVert maintains comprehensive policies and procedures to support and reinforce this AML policy.
PayVert employees play an active role in safeguarding the Company’s services from being misused by criminals and terrorists for purposes such as money laundering or financing of terrorism.
The goals of this policy are as follows: To ensure that PayVert fully complies with all relevant laws, regulatory frameworks, and industry-specific requirements. To shield the company and its employees from the risks arising from violations of legal, regulatory, and supervisory obligations; To safeguard the company’s reputation from potential damage linked to involvement in money laundering or terrorist financing activities; To actively contribute to the global fight against crime and terrorism.
To accomplish these objectives, PayVert ensures that:
Each employee fulfills their individual responsibilities as suited to their role and position within the Company.
Commercial interests or client loyalty will not override the Company’s commitment to anti-money laundering efforts. The organization supports the Anti-Money Laundering Reporting Officer in executing their responsibilities;
It upholds anti-money laundering policies and procedures that delineate the actions staff must take in their roles, while continually assessing these policies to guarantee their relevance.
The comprehensive AML framework for PayVert includes:
Anti-Bribery and Corruption Policy;
AML Risk Assessment Procedures;
Code of Business Ethics;
Customer Due Diligence Procedures;
Disciplinary Framework;
PEP & Sanctions Screening Procedures;
Supplier and Third-Party Integrity Policy;
Protocol for Reporting Suspicious Activities;
Policy for Submitting SARs; and
Whistleblower Protection Policy.
Money laundering refers to the act of concealing the origins of funds obtained through illegal activities. Conversely, terrorist financing involves providing financial resources for terrorist operations. The utilization of products and services by money launderers and terrorists poses considerable criminal, regulatory, and reputational risks to the Company.
This policy aims to guide the Company in its approach to managing Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) efforts.
It supports management’s goal of mitigating the following risks:
Money laundering;
Terrorist financing;
Sanctions violations;
Politically Exposed Persons (PEPs);
Legal and regulatory risks.
PayVert is committed to avoiding three main categories of offenses related to money laundering:
1. Deliberately aiding in the concealment of, or arranging for the acquisition, use, and/or possession of, criminal assets;
2. Neglecting to report knowledge or suspicion, or failing to act when there are reasonable grounds to believe that another individual is involved in money laundering or terrorist financing;
3. Providing information that may compromise an investigation or alerting someone about it.
There are notable similarities between the movement of funds for terrorist activities and the laundering of illicit funds; many terrorist organizations maintain strong connections with organized crime. Nevertheless, there are two key distinctions between terrorist funding and criminal assets.
Firstly:
Only minimal amounts are needed to carry out individual terrorist acts, which complicates the tracking of terrorist funds;
Secondly, terrorists can be financed through legitimately obtained income, such as donations to charitable causes, making it challenging to pinpoint the moment when legitimate funds transition into terrorist financing.
PayVert ensures that its employees are well-informed about AML awareness along with the relevant policies and procedures.
PayVert employs a risk-based strategy to manage the risks associated with its operations, taking into consideration applicable legislation and industry guidelines.
The Anti-Money Laundering Reporting Officer (AMLRO) is tasked with ensuring that an AML risk assessment is conducted and reviewed on a regular basis. The identified risks should inform the effectiveness of PayVert’s policies, procedures, and control systems designed to prevent and detect money laundering or terrorist financing activities.
This risk-based approach seeks to manage and mitigate money laundering and terrorist financing risks in the most cost-effective and proportionate manner.
The AMLRO evaluates the money laundering and terrorist financing risks based on the following criteria:
Customer risk – specific categories of customers and the resulting business relationships;
Payment risk – the payment methods available and how vulnerable their specific attributes are to money laundering or terrorist financing threats.
Geographical risk – risks associated with specific geographic factors.
Product risk – the products offered and the extent to which their characteristics may appeal to money laundering or terrorist financing activities.
Supplier/Third-Party Risk – risks involved in onboarding new clients or suppliers without a clear understanding of business ownership or other related AML concerns.
Technological Risk – evaluates the vulnerabilities in the company's technology and its susceptibility to money laundering or terrorist financing.
Employee Risk – assesses the risks posed by the actions or behavior of company employees.
Regulatory Risk – addresses the potential for non-compliance with licensing and regulatory requirements.
PayVert acknowledges that risks evolve over time and continuously updates its risk management processes as part of its broader risk management framework.
The "Know Your Customer" (KYC) requirement involves collecting detailed information about a customer’s identity and gaining sufficient knowledge of the purpose for which they seek to establish a relationship with a financial institution. This knowledge is applied to all transactions initiated by the customer, helping prevent the institution from being used to launder criminal proceeds and detect suspicious activities.
As such, PayVert has implemented clear, written procedures for verifying the identity of individuals opening new accounts. These procedures specify the types of information the institution will collect from customers and how each customer's identity will be verified.
PayVert will not establish a business relationship until all relevant counterparties are properly identified and the nature of the intended business is fully understood. Once a business relationship is confirmed and normal activity is established, any unusual behavior will be investigated to determine if it suggests money laundering.
The primary requirement for knowing your customer in relation to money laundering is that PayVert must be assured that a prospective customer is indeed who they claim to be. PayVert will not engage in any financial transactions or provide advice to a customer or potential customer unless it is confident about the individual's identity. If a customer is acting on behalf of another party, PayVert is obligated to verify the identities of both the customer and the agent/trustee, unless the customer is a regulated financial institution in the country.
The Nature and Level of Business to Be Conducted
Sufficient information must be gathered regarding the nature of the business the customer plans to conduct, including the expected or typical transaction patterns. The information collected at the outset should encompass:
- The type of relationship with PayVert, such as a Merchant or Consumer;
- The nature of the activities to be undertaken;
- Details about the customer’s occupation, business activities, and sources of wealth or income.
Adequate measures should be taken to keep this information current as opportunities arise, such as when an existing customer opens a new account. Any information gathered during interactions with the customer should be updated in the existing account whenever possible, ensuring that current customer information is readily accessible to the AMLRO or relevant regulatory authorities.
PayVert has implemented a risk-based strategy in its KYC policy to address customers deemed to have a "higher risk" than others. The risk levels associated with customers may vary based on the type of customer, the services provided, and the customer's transaction capacity. Customers identified as "higher risk" must undergo enhanced due diligence investigations, which include the following:
- Non-face-to-face customers, such as Consumers.
- Politically Exposed Persons (PEPs).
For these high-risk entities, the KYC approach will involve Enhanced Customer Due Diligence (ECDD) techniques. The ECDD procedures should consist of:
- Identifying the customer and verifying their identity using reliable and independent source documents, data, or information.
- Conducting ongoing due diligence on the business relationship and scrutinizing transactions carried out during that relationship to ensure that the transactions align with PayVert’s understanding of the customers, their business activities, and risk profiles, including the source of funds when necessary.
Identity is characterized by a set of attributes, including the names used, date of birth, and the digital address associated with the customer, all of which can uniquely identify an individual or legal entity.
Identity must be verified whenever a business relationship is initiated and an account is opened. For PayVert, a business relationship does not encompass simply providing information about service availability or engaging in preliminary discussions prior to forming a relationship. Once the identification process is satisfactorily completed and the business relationship is established, there is no need to re-verify the customer's identity for subsequent transactions as long as the contract or activity is ongoing and records related to that customer are maintained. However, additional evidence of identity may be required if a customer requests to modify their daily transaction limit.
Every Retail Manager must ensure that they are engaging with a legitimate individual or organization (natural, corporate, or legal) by obtaining sufficient identification evidence at all times.
The organization or business must have the legal authorization to sell the merchandise or services offered.
All items must be eligible for sale through PayVert.
The organization or business must be the direct provider of the product or service, with no intermediaries involved.
Proof of identification (e.g., Passport, TIN, Driver’s License) must be provided for the owner(s) of the business.
Additional documentation, such as licenses from regulatory authorities, is necessary and will be inspected by PayVert for businesses engaged in specialized activities, such as betting and lottery.
KYC will be structured according to the desired transaction limits of the users. There are three (3) distinct KYC levels, each requiring a different set of identification from the user.
Level 1: Basic KYC – Transactions below GHC 100.00
The customer must provide a phone number.
PayVert will verify the user's name through the scheme or wallet provider.
Level 2: Intermediate KYC – Transactions exceeding GHC 100.00 but not exceeding GHC 30,000
The customer must provide a phone number.
PayVert will confirm the user’s name through the scheme or wallet provider.
The customer must provide identification details, such as a Voter ID.
PayVert will verify the provided ID against official records.
Level 3: Advanced KYC – Transactions exceeding GHC 30,000.00
The customer must provide a phone number.
PayVert will confirm the user’s name through the scheme or wallet provider.
The customer must provide an acceptable form of national identification, such as a Passport, National ID, Voter ID, or Driver’s License.
PayVert will verify the customer's ID using system connectivity with relevant identity verification agencies.
Upon the initial login to the mobile application, the consumer will be requested to provide KYC information. If a user attempts a transaction that necessitates a higher KYC level than their current one, PayVert’s system will display an error message.
When evaluating an application submitted by a group, PayVert ensures that the organization or society is properly registered and requests a resolution from the Board or Executives. PayVert verifies the organization’s identity by confirming its registration with the company registry.
For government entities and their agencies, a certified copy of the resolution or any other documentation authorizing the opening of the account or conducting the transaction is required, along with proof that the official representing the agency has the appropriate authority to act.
Regarding foreign consulates, it is essential to verify the status of applicants seeking to open accounts or perform transactions in the names of resident foreign consulates, as well as any supporting documents by referencing the relevant industry regulator or competent authority.
The Company utilizes an external service provider to conduct screenings of customers against recognized Sanctions Lists and Politically Exposed Persons (PEPs) lists. Individuals will be screened both during initial registration and on an ongoing basis (monthly).
The term ‘politically exposed persons’ (PEPs) refers to individuals who hold high public office. According to the Anti-Money Laundering Act 2008 (Act 749), firms are required to implement additional measures, known as “enhanced due diligence,” when engaging with PEPs, as well as their family members or close associates.
The company has established appropriate risk-management systems and procedures to identify whether a customer or the beneficial owner is (a) a politically exposed person (a “PEP”) or (b) a family member or known close associate of a PEP, and to manage the enhanced risks that arise from the relationship with such customers.
Examples of prominent public functions include:
Any match or potential match to a PEP requires approval from the AMLRO and/or further guidance before allowing the customer to open an account with the company. If approval is granted for a PEP, enhanced due diligence may be necessary (such as additional documentation). Furthermore, all PEPs will be subject to ongoing monitoring of their account activity, conducted at least monthly, to ensure that account operations remain consistent and to identify any sudden changes in activity or behavior.