Policy and procedure on due diligence

  • It is our policy to undertake a whole-firm risk assessment and ensure that evidence of identity is obtained and retained as appropriate to that risk assessment for all clients
  • Risks are grouped in to categories [specifically – eg client risk, service risk, geographic risk, sector risk, delivery channel risk]

  • All risks, including those not within this category, will be assessed in isolation 

  • Evidence will be obtained before work is commenced on the client and when periodic reviews are undertaken (if more evidence is required then the client will ask to provide more document  and when changes occur during the relationship with the client activity client will be subjected to provided more document ).

Policy and procedure on assessing risk

  • Flango will analyse the money laundering and terrorist financing (MLTF) risks it faces and make proportionate responses to them. Fintpay will tailor its responses in proportion to its perceptions of risk, which are comprised of evidence-based decision-making to enable fintpay to concentrate resources on the greatest threats. Fintpay will document this risk assessment.

Fintpay will talk the following step

  • Identify the specific MLTF risks faced by different areas of our service and the different risk categories

  • To reduce the level of net risk (as calculated above) to an acceptable level, consider what mitigating steps fintpay can take; this would include reviewing the systems and controls, and ensuring staff understand and properly apply these


Policy and procedure on reporting

  • It is our policy to report all suspicions identified to the National Crime Agency (NCA),FBI,and Interpol where required

  • It is in our policy to act and suspend any suspicions account

Policy and procedure on record keeping (client due diligence and money laundering issues only)

  • It is our policy to maintain records of identification and consideration of money laundering issues for the entire period that we act for the client and for five years after we cease to act in accordance with the regulations. If we are required to retain them under statutory obligation, or to retain them for legal proceedings, or by client consent, the records will be retained for not more than 2 years after we cease to act.
  • The client will be asked to give permission for the retention of copies of the documentation, which will be maintained in a secure sever


Policy and procedure on third-party reliance

It is not generally our policy to give permission to a third party to rely on information obtained by us.


Fintpay may rely on information obtained from appropriate third parties to complete all or part of the CDD. Fintpay will have a written agreement in place with such a third party to ensure that the other party will provide the CDD documentation immediately on request.



Last updated  by Fasan Miracle Fintpay Staff April 2020.