AML Policy

Wallet Money Terminal as a payment gateway provider takes the responsibility and accountability to ensure compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) laws and regulations. We take every measure to ensure that all available safeguards are implemented to prevent any violations of the AML/CFT ordinances, including the following:

  1. Our board of directors and senior management are responsible for ensuring strong governance and sound AML/CFT risk management and controls.
  2. We shall sanction territories that have evidence of adverse news or relevant public criticism of a country or jurisdiction, including FATF public documents on High Risk and Non-cooperative jurisdictions; the AML/CFT laws, regulations and standards of the country or jurisdiction.
  3. We shall incorporate the AML/CFT Policy of Payment Provider into our enterprise-wide ML/TF risk assessment process. To keep our enterprise-wide risk assessments up-to-date, we should review our risk assessment at least every two years or when material trigger events occur, whichever is earlier.
  4. Where the ML/TF risks are identified to be higher, we shall take enhanced CDD (ECDD) measures to mitigate and manage those risks.
  5. Continuous training of all relevant staff in order to ensure everybody is fully updated on the AML/CFT ordinances, and appropriate measures to enable frontline staff to discern whether a transaction may be suspicious.
  6. A risk-management approach to achieve appropriate control and oversight and, accordingly, to determine the appropriate levels of due diligence and monitoring to be applied.
  7. Safekeeping of all documents obtained in the process of ascertaining the identity of the customer and in connection with the transactions. These shall be kept throughout the business relationship with the customer and for a period of six years after its termination.
  8. Keep the policies and procedures under regular review for the assessment of the effectiveness of our law-abiding procedures, Wallet Money Terminal reserves the right not to conduct any business with a party suspected of, or directly involved in, any wrongdoings, like, for instance, money laundering, or where funds have been obtained by way of illegal activities.