1. Introduction

1.1. Fintechnet Solutions Ltd is a financial technology company registered in the United Kingdom, with its legal address at 124 City Road, London, UK, EC1V 2NX. We specialize in providing payment services under the Pay4Bit brand, offering convenient, secure, and reliable transaction solutions for individuals and businesses.
1.2. This Anti-Money Laundering (AML) Policy is designed to ensure compliance with legal requirements for preventing money laundering (AML) and counter-terrorist financing (CTF). We are committed to adhering to established regulations and implementing effective mechanisms to protect our platform from illicit financial activities.
1.3. Fintechnet Solutions Ltd operates in accordance with UK legislation and international standards, including:

• The UK Criminal Finances Act 2017
• The Proceeds of Crime Act 2002 (POCA)
• Regulations of the Financial Conduct Authority (FCA) and HM Treasury
• EU Anti-Money Laundering Directives (AMLD 4, 5, 6)
• Recommendations of the Financial Action Task Force (FATF)

1.4. Fintechnet Solutions Ltd is committed to complying with all applicable laws and regulations by:

• Implementing a Know Your Customer (KYC) policy and Customer Due Diligence (CDD) procedures.
• Using a risk-based approach (RBA) to monitor transactions.
• Maintaining internal records and reporting suspicious transactions
to the relevant authorities
(Suspicious Activity Reports – SARs – to the UK’s National Crime Agency, NCA).
• Providing AML/CTF training for employees.

1.5. This Policy applies to:

• All employees and executives of Fintechnet Solutions Ltd.
• All customers and users of the Pay4Bit service.
• All partners and third-party service providers.
• All transactions and activities conducted on the Pay4Bit platform.

1.6. To ensure AML policy compliance, a Money Laundering Reporting Officer (MLRO) is appointed, responsible for:

• Monitoring and assessing the effectiveness of the AML/CTF program.
• Reporting suspicious activities to the relevant authorities.
• Ensuring that employees receive appropriate training and guidance on AML/CTF procedures.
• Liaising with regulators and law enforcement agencies

2. General Provisions

2.1. Fintechnet Solutions Ltd applies a Risk-Based Approach (RBA) to identify, assess, and mitigate risks associated with money laundering and terrorist financing. This approach includes:

• Categorizing customers and transactions based on risk levels (low, medium, high).
• Conducting enhanced due diligence (EDD) for high-risk customers.
• Regularly reviewing and updating risk assessment policies.

2.2. To ensure compliance with AML regulations, Fintechnet Solutions Ltd implements CDD procedures, which include:

• Verifying the identity of clients using official documents (passport, ID card, or other available sources).
• Evaluating the customer’s risk level based on their profile, transaction patterns, and geographic location.
• Continuously reviewing transactions to detect suspicious activities and ensure compliance with AML regulations.

2.3. The company maintains a system for detecting, reviewing, and reporting suspicious transactions. Key measures include:

• Using automated and manual monitoring tools to track unusual transaction patterns.
• Requiring employees to report any suspicious activity to the Money Laundering Reporting Officer (MLRO).
• Submitting Suspicious Activity Reports (SARs) to the UK National Crime Agency (NCA) when necessary.

2.4. Fintechnet Solutions Ltd ensures proper record-keeping and compliance with data protection regulations by:

• Retaining customer and transaction records for at least five (5) years after the end of the business relationship.
• Storing information securely in compliance with UK GDPR and Data Protection Act 2018.
• Ensuring that records are available for regulatory review upon request.

3. Customer Identification and Verification Procedures

3.1. Fintechnet Solutions Ltd adheres to a strict Know Your Customer (KYC) policy to prevent financial crimes, fraud, and identity theft. The company requires all customers to undergo an identification process before establishing a business relationship.
3.2. The company applies a tiered approach to customer verification based on risk levels:

3.2.1. Simplified Due Diligence (SDD) – Low-Risk Customers. For low-risk customers, the company collects basic information about their identity and activities. This includes:

• Verification that the customer operates in a low-risk industry and jurisdiction.
• No additional documentation is required unless risk indicators change.

3.2.2. Standard Due Diligence (CDD) – Regular Customers. For standard customers, the company requires documentary verification, which includes:

• A valid government-issued ID (passport, national ID card, or drivers license).
• Proof of address (utility bill, bank statement, or official correspondence not older than 3 months).
• Basic information about the source of funds (e.g., employment details or business activity).

3.2.3. Enhanced Due Diligence (EDD) – High-Risk Customers. For high-risk customers, the company conducts Enhanced Due Diligence (EDD), requiring additional documentation and verification steps:

• Submission of multiple identity documents for cross-verification.
• Detailed proof of source of funds and wealth (e.g., tax returns, employment contracts, company ownership records).
• Additional background checks, including screening against sanctions lists, politically exposed persons (PEP) databases, and watchlists.
• In some cases, a video verification process or an in-person meeting may be required.

3.3. The company utilizes a combination of manual and automated verification processes:

• Electronic identity verification (EIDV) through trusted databases.
• AI-driven fraud detection to identify inconsistencies or forged documents.
• Ongoing re-verification of customer information when risk levels change.

3.4. Ongoing Monitoring of Customer Activity. Fintechnet Solutions Ltd continuously monitors customer transactions to detect suspicious activity:

• Automated transaction monitoring to flag unusual patterns.
• Regular risk reassessment, updating customer risk levels if their activity changes.
• Screening against updated sanction lists, PEP lists, and adverse media reports.
• Trigger-based review (e.g., sudden large transactions, unusual transaction frequency, or activity in high-risk jurisdictions).

3.5. Fintechnet Solutions Ltd reserves the right to refuse service to customers who fail to provide the necessary identification documents or whose activities raise suspicion of money

4. Applicable Measures

4.1. To ensure compliance with AML regulations and prevent financial crimes, Fintechnet Solutions Ltd reserves the right to apply the following measures in cases where a customer`s activity poses a risk or violates the company`s policies.
4.2. Customers who refuse to undergo identity verification or fail to provide the required documents within the specified timeframe may be denied access to the Pay4Bit services. The company reserves the right to block or restrict access until full compliance with KYC requirements is achieved.

4.3. If a transaction is flagged as suspicious based on internal monitoring and fraud detection systems, Fintechnet Solutions Ltd has the right to:

• Place the transaction on hold for up to 14 days for further investigation.
• Request additional verification documents from the customer to confirm the legitimacy of the transaction.
• Report the transaction to the relevant regulatory and law enforcement authorities if necessary.

4.4. Fintechnet Solutions Ltd reserves the right to request additional customer verification at any moment, including but not limited to:

• Reverification of identity documents if there are discrepancies or inconsistencies in customer data.
• Source of funds and wealth verification in case of unusual or high-value transactions.
• Additional security checks if the customer engages in activity that increases their risk profile.

Failure to provide the requested information may result in temporary suspension or termination of service.

4.5. The company strictly complies with sanctions and anti-terrorism regulations. If a customer is found to have direct or indirect connections with:

• Sanctioned individuals, organizations, or jurisdictions (as per OFAC, EU, UN, and UK sanctions lists).
• Terrorist organizations or individuals engaged in illegal activities.
• Fintechnet Solutions Ltd has the right to immediately terminate the business relationship and report the case to the relevant authorities.

4.6. If the company incurs financial losses, fines, or legal expenses due to a customer`s violation of this AML policy, Fintechnet Solutions Ltd has the right to:

• Deduct the incurred losses from the customer`s account balance.
• Recover damages through legal proceedings, if necessary.
• Refuse any further service provision to the customer.

5. Dispute Resolution

5.1. In the event of a dispute related to payments or transactions, Fintechnet Solutions Ltd reserves the right to take appropriate actions to protect all parties involved and ensure compliance with financial regulations.

5.2. If a transaction becomes the subject of a dispute, Fintechnet Solutions Ltd may:

• Place the transaction on hold until the dispute is resolved.
• Deny service to the customer if fraudulent or malicious intent is suspected.
• Request additional documents from all involved parties to assist in resolving the dispute.

5.3. Customer`s Right to Participate in the Dispute. A customer whose transaction is under dispute has the right to:

• Provide supporting evidence (e.g., receipts, communication logs, proof of service delivery) to defend their position.
• Cancel the transaction at their discretion if they deem it necessary.

5.4. If a customer chooses to participate in the dispute resolution process, they must pay a 25 EUR fee, regardless of the outcome. If the customer loses the dispute, an additional 40 EUR fee will be deducted to cover payment system processing costs.

5.5. Individuals or businesses affected by Pay4Bit customers actions have the right to file a complaint by:

• Contacting Fintechnet Solutions Ltd directly at support@pay4bit.net, providing details of the merchant or transaction in question.
• Initiating a chargeback request with their bank if they believe the transaction was unauthorized or fraudulent.

Last updated: 19.02.2025 - 00:00