PayCly (from now on – the company or PayCly) is a provider of technical processing services.
The company shall conform to the local Acts' requirements on Prevention of Money Laundering and Terrorism Financing and the requirements of other laws and regulations to the extent in which they relate to PayCly's operations.
The company shall strictly comply with the policies and procedures outlined in this document (hereafter – the policy).
PayCly develops this policy and may introduce amendments and additions to it at its own volition and oversee compliance with its provisions and requirements.
The client shall read the Policy before accepting PayCly's Terms and Conditions. The client's consent of the Terms and Conditions, as we as Clients' making transactions in the PayCly system after accepting the Terms and Conditions, shall signify the client's acceptance of all the current version provisions of this Policy.
To oversee and execute the procedures contemplated in the Policy, PayCly appoints a Compliance Officer.
The Compliance Officer is liable for the collection, analysis, and investigation of information on any suspicious actions and the practice of the company's employees pertaining to the relevant procedures; the Merchant Services Officer shall determine the guidelines and rules for carrying out customers' identification, reviewing and monitoring unusual transactions and technical features of the PayCly's implementation of this Policy.
For clients' identification, PayCly requests the following documents:
PayCly conducts the KYC (Know Your Customer) verification procedures to avoid the risk of being held liable and protect itself from a customer's attempting to use the company to carry out illegal activities.
PayCly evaluates customers' transactions and collects and stocks data and essential facts pertaining to customers, potential clients, and their transactions as part of the KYC procedures.
After taking out the identification procedures pertaining to a client, PayCly stores the info obtained in the client's file. The company is under commitment to carry out the identification procedures related to a client once.
PayCly is committed to protecting client's rights and the confidentiality of their data. PayCly collects personal information from the client only to the extent necessary to ensure PayCly properly providing service to clients. Such personal information about clients and former clients may be disclosed to third party only a limited number of circumstances, under the applicable laws and agreements between PayCly and the client.
PayCly shall carefully maintain customer's file, including the statement, transaction reports, receipts, notes, internal correspondence, and any other information related to the customer in electronic format for as long as may be required by the underwriting teams at the relevant acquiring banks/processors that customer makes use of.
Any transaction that may be related to money laundering activities shall be considered to be suspicious activities.
Areas for determining that a specific transaction is suspicious may be the personal sights and experience of the Company's employees and the information received or identified.
The Merchant Services Officer shall continuously observe and update the company's systems to detect suspicious activities.
Following the applicable laws and international organizations' requirements, the Company may, where appropriate and without the obligation of obtaining the Customer's approval or informing the client, notify regulating and/or law enforcement agencies of any suspicious transactions.
PayCly shall periodically refer to and consult the lists published by the local officials and international organizations that include lists of known terrorists or persons speculated of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subjected to the OFAC sanctions. These jurisdictions do not give a sufficient level of anti-money laundering procedures, and countries directed to sanctions to decide whether the Company's Customer or potential Customer and/or such Customer's country of jurisdiction is involved in the above lists.
PayCly shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions' compatibility with PayCly's knowledge of its customers, their business and, when necessary, their source of funds.
To execute some of its business functions, PayCly may use third-party service providers. PayCly shall make an effort to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any admitted investigation and filed lawsuits against any such third-party service providers. PayCly shall also decide whether a third-party provider has obtained all the necessary licenses, permits, and approvals prior to establishing a business relationship with such a third-party service provider.
Concerning its staff, PayCly shall carefully review all candidates for employment and determine whether a new employee's activities fall in the category that is susceptible to money laundering activities. The Company has also developed and implements several personnel training programs on customer identification methods and the prevention of money laundering activities.
Government authorities of various countries and, in some cases, international organizations may impose stiff civil and criminal penalties against any person that infringes the laws and guidelines referred to in paragraph 1.2 of the Policy. Such civil and criminal legal penalties may carry fines in the amount of up to hundreds of thousands or even millions of dollars. The term of criminal punishment may be many years in prison. Besides, government authorities may confiscate any property involved in criminal violation of these laws and ordinances, including firms, bank accounts, or any other assets associated with criminal offences.
Under certain conditions, companies may be considered criminally responsible for the actions of their employees. In this regard, our corporate customers' employees need to have adequate knowledge in this sphere; it is also important that such Corporate Customers so crucial the compliance of their employees' actions with the said laws and regulations.
The Corporate Client (the Corporate Client's authorized employee) certifies that they have gone through and conceded this notice and that they (or their company) shall function in full compliance with the terms and standards described in the Policy and comply with all applicable laws and other ordinances and conditions governing its activities as a Corporate Customer.
The Corporate Client (the Corporate Client's authorized employee) confirms that they are responsible for their actions following the effective laws in the field discussed in this Policy and shall bear responsibility pertaining to failure to comply with such laws.