Close this search box.

AML/KYC Policy

Gasmerlo Limited (“Paymentcy”, “Company”,”We”, “Us”) is a technology provider of payment processing services.

  1. Introduction

The Company endeavors to maintain and stay compliant with the local acts pertaining to Prevention of Money Laundering and Terrorism Financing as well as other laws and regulations that remain applicable to the Company.

The Company warrants that it shall strictly adhere to the procedures outlined in this Policy and oversee compliance with its provisions and requirements.

The Company may from time to time refresh this Policy by introducing amendments at its own discretion.

The User (“Customer”, “User”, “Users”) shall read this Policy before accepting the Terms of Use of Paymentcy. The User’s acceptance to the Terms of Use as well as executing any transaction through the System after accepting the Terms of Use, shall go on to mean the unambiguous acceptance of the latest version of this Policy.

The updated version of the Policy is available on:

  1. Merchant AML Officer

The Merchant AML Officer appointed by the Company shall remain responsible for the collection, analysis, and investigation of information on any activity deemed to be suspicious, and for the training of the Company employees so that they in turn ensure compliance. The Officer determines the rules and procedures for carrying out Customer Identification, monitoring and reviewing unusual transactions and technical features of the implementation of this Policy by the Company.

  1. Customer Identification Procedure

For the purposes of Customers’ identification, the Company requests the following documents:
  • Certificate of incorporation or equivalent
  • Certificate of registered office or equivalent
  • Certificate of directors and secretary or equivalent
  • Certificate of shareholders or equivalent
  • Memorandum and articles of association of the legal person
  • Document confirming the powers and authority of the person authorized to act on the company’s behalf.
  • Recent copy of a bank statement, utility bill or Rental agreement in order to verify the operational office address.
  • Good standing letter
For the Directors, UBOs and Shareholders the following KYC documents will be collected:
  • Proof of Identity (POI)
  1. Valid passport; or
  2. Valid driving license; or
  3. National Identity card.
  • Documents must be valid and with at least 3 months to expiration.
  • Paymentcy might take steps to confirm the authenticity of documents and information provided by the Customers.
  • Paymentcy might investigate certain Customers who have been determined to be at high risk or suspicious by asking more documents and information.
  • Paymentcy reserves the right to verify a customer’s identity and address in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Customer) or deemed at high risk by Paymentcy sole discretion.
  • Paymentcy reserves the right to request up-to-date documents from the Customer, even though they have successfully completed the identification process in the past.
  • Customer identification information will be collected, stored, shared and protected strictly in accordance with the Paymentcy Privacy Policy and related regulations.
  • Proof of Residence (POR)
  1. Recent Utility bill; or
  2. Recent bank account statement; or
  3. Local Authority Tax Bill.
  • All documents must clearly show the Customer full name and full address and be no older than 3 months.
  • Accepted Utility documents: water/electricity/gas/cable/landline phone bills.
  1. Know Your Customer Verification Procedures

The Company conducts the Know Your Customer (KYC) method of verification in order to mitigate risks and protect its interests from Users attempting to carry out illegal activities by using the Company and its Systems. In furtherance of the procedure of conducting KYC, the Company also evaluate the transactions of the Users in addition to collecting and storing essential facts pertaining to the Users, potential Users and their transactions.

The Company is under obligation to carry out the identification procedures through KYC for every Customer at least once, and once the User has been identified, the information is stored in the file on the name of the User. The Company is focused on securing User’s privileges and the privacy of their information. The Company gathers personal data from User’s just to the degree it requires to guarantee the Company’s appropriately offering services to the Users. Personal information about the Users and previous Users might be revealed to third parties only in a limited number of circumstances, in accordance with the laws and policies between the Company and the User. The Company will cautiously maintain the records of the users, including statements, transaction reports, receipts, notes, internal correspondences, and other documents identified with the User in electronic format for as long as may be needed by the underwriting teams at the relevant acquiring banks/processors that the User utilizes.

  1. Suspicious Activities: Detection and Identification

Any transaction that might be related to activities of money laundering shall be referred to as suspicious activity. The reasons for determining whether a transaction is suspicious or not may be entirely personal observation of the employees of the Company in addition to information received or identified. The appointed Merchant AML Officer continuously updates and monitors the systems used to detect suspicious activities.

In accordance with the applicable laws, regulations of international organizations, the Company shall cooperate with any request emanating from an authorized law enforcement authority for any suspicious activities, without obtaining the consent of the User. The Company will periodically refer to lists published by local and international organizations of known or suspected terrorist activities, high risk countries, terrorist organization, countries with OFAC sanctions, jurisdictions that cannot provide sufficient degree of anti-money laundering procedures including countries subject to sanctions to determine whether the Company’s User or potential User, and/or User’s country of jurisdiction is included in the lists. The Company shall continuously conduct due diligence procedures to its Users and scrutinize their transactions to ensure the compatibility of these transactions with the knowledge the Company already has on its Users, their businesses and when appliable, their source of funds.

  1. Training

The Company training of employees plays a vital role in the effectiveness of the Company’s ongoing monitoring. The Company delivers training to help employees understand regulation, compliance, identification procedures, techniques of prevention of money laundering, fraud awareness, corruption and sanctions.

  1. Civil and Criminal Penalties

Government Authorities of various nations may force serious civil and criminal punishments against any individual that abuses the Prevention of Money Laundering and Terrorism Financing Laws and regulations as referred to within this Policy. Such civil and criminal penalties may include fines of up to millions of dollars, and the term of criminal punishment might be up to several years in prison. Government authorities may seize any property associated with criminal violation of these laws and regulations, including Companies’ bank accounts, or other property that might be related with the criminal violations. Under certain circumstances, The Customers may be held criminally liable for the actions of its employees, hence it is important for the employees of the User to have the requisite knowledge and the Customer should ensure compliance of their employees with said rules and regulations.

  1. Compliance acknowledgment Statement

The Customer and their authorized employees certify that they have read and understood this Policy and that they shall operate in full compliance with the standards set by the Policy and comply with all the applicable laws and regulations and requirements governing their activities. The Customer and its authorized employees further acknowledge that they are responsible for their own actions in relation to the relevant applicable laws and shall bear responsibility in the event of failure to comply with such laws.    

Quick contact
The company

With over 10 years of experience in payments for higher risk industries, we know your business better than anyone else.