AML/CFT Policy

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AML/CFT Policy – Exim Pay

Our Commitment

Exim Pay is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. We have established a strong Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) framework to prevent, detect, and report money laundering, terrorism financing, and other financial crimes.

Exim Pay operates with a zero-tolerance approach to illegal financial activity and applies strict controls to protect our customers, partners, and the financial system.

Compliance Standards

Exim Pay follows applicable AML/CFT laws, regulations, and supervisory guidance in the jurisdictions where we operate. Our compliance framework is guided by international best practices, including recommendations by the Financial Action Task Force (FATF) and other recognized standards.

Customer Due Diligence (KYC)

Exim Pay applies robust Know Your Customer (KYC) and Customer Due Diligence procedures to verify and identify our customers before providing financial services. These measures include:

  • Verifying customer identity using valid identification documents and reliable sources
  • Collecting and validating customer information (name, address, date of birth, occupation, source of funds, etc.)
  • Conducting risk profiling and screening during onboarding
  • Applying additional verification for higher-risk customers or transactions

We may request additional information at any time to ensure ongoing compliance.

Enhanced Due Diligence (EDD)

For higher-risk customers, transactions, or jurisdictions, Exim Pay applies Enhanced Due Diligence (EDD) measures, which may include:

  • Additional identity verification and supporting documents
  • Review of source of wealth and source of funds
  • Increased transaction monitoring
  • Senior management approval where required

Sanctions & Watchlist Screening

Exim Pay screens customers and transactions against relevant sanction lists and watchlists, including:

  • UN sanctions lists
  • Local or regional sanctions and regulatory lists
  • Internal high-risk lists

We do not provide services to individuals or entities that are sanctioned, prohibited, or involved in unlawful activities.

Transaction Monitoring

Exim Pay uses risk-based monitoring systems to detect suspicious behavior and unusual transaction patterns. Monitoring includes, but is not limited to:

  • Unusual transaction sizes or frequency
  • Rapid movement of funds inconsistent with customer profile
  • Transactions involving high-risk countries or counterparties
  • Attempts to avoid identification or reporting requirements
  • Structuring or smurfing patterns

When suspicious activity is identified, we take appropriate action, including restricting transactions and reporting as required.

Reporting Suspicious Activity

Exim Pay complies with legal reporting obligations and will file Suspicious Transaction Reports (STRs) or other required reports with relevant authorities when necessary.

We may also freeze or suspend accounts and transactions where required by law or where risks cannot be managed.

Record Keeping

Exim Pay maintains accurate records of customer identification data, transaction history, and compliance actions, as required by applicable laws. Records are retained securely for the legally required period and are made available to authorities upon lawful request.

Employee Training & Awareness

Exim Pay ensures that employees, contractors, and relevant stakeholders receive AML/CFT training appropriate to their roles. Training is conducted regularly to ensure awareness of:

  • AML/CFT legal requirements
  • Risk indicators and red flags
  • Reporting procedures
  • Customer due diligence responsibilities

Risk-Based Approach

Exim Pay applies a risk-based approach to identifying, assessing, and managing money laundering and terrorism financing risks. This includes evaluating risks related to:

  • Customers
  • Products and services
  • Delivery channels
  • Geographic locations
  • Transaction behavior

Data Protection & Confidentiality

Exim Pay protects customer data and ensures confidentiality in accordance with applicable data privacy laws. Information may only be disclosed to authorized regulators, law enforcement agencies, and financial intelligence units when legally required.

Policy Review & Updates

This AML/CFT Policy is reviewed and updated periodically to ensure it remains effective and aligned with changing regulatory requirements and emerging financial crime risks.