FINTPAY ANTI-MONEY LAUNDERING POLICIES
Policy and procedure on due diligence
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
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
Policy and procedure on record keeping (client due diligence and money laundering issues only)
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.