PAYHOF

Blacklisted Jurisdictions and AML Risk Appetite Statement

  September 2020

Address: Žalgirio g. 90-100, LT-09303 Vilnius

Phone: +37052080669

Email: info@payhof.com

UAB Montify LT (trading name Payhof, here and after Payhof) is an Agent of UAB Payswix that is authorized by the Central Bank of Lithuania (Nr. 21) for the issuing of electronic money.

This statement describes Joint Payhof and GNI AML Risk Appetite and provides the framework through which the Business describes the level and types of AML risk that Payhof is willing to incur in executing its broader business strategy.

AML Risk Profile

Payhof AML Risk Profile is composed of products and services, customers (individuals and entities) and country risk. Within these risk categories and as a result of the global reach in providing a service Payhof could be unwittingly used for the furtherance of financial crime. Financial crime – Payhof must comply with legal requirements to deter and detect financial crime, which includes money laundering and terrorist financing.

Payhof is fully committed to comply with respective applicable regulations and industry best standards, and has implemented internal policies, procedures and detailed instructions to prevent itself from being used to facilitate money laundering, financing of terrorism or engage in other unlawful activities such as bribery, fraud and corruption or tax evasion.

    Conduct Risk

The Company has zero tolerance for financial crime, regulatory breaches and any attempt to circumvent the Company’s financial crime policies and controls. The Company adheres to the following core principles:

- To show zero tolerance for facilitation of financial crime, money laundering, financing of terrorism and fraud;
- To avoid knowingly conducting business with individuals or entities believed to be engaged in an inappropriate and unlawful behavior;
- To avoid risks that could jeopardize the Company strategic plans, including activities that could make the Company vulnerable to any type of public or private litigation or enforcement that could be damaging to the company reputation and cause deterioration of relationship with regulators;
- To avoid or seize operating any customer segment line, for which the management believes that Company’s control mechanisms cannot protect the Company from risks that exceed the tolerance threshold.

The Company has zero appetite for establishing or maintaining relationship with a client or counterparty relationship who appears to be on sanctions lists, their beneficial owners, representatives or facilitating transactions related to sanctioned countries, persons or activities, regardless of the Customer profitability, transaction amount or any other considerations.

    Customer risk

Payhof doesn’t establish business relationship with the below business sectors:

- Unregulated/unlicensed Financial Institutions
- Unregulated (or activity without registration) Virtual Asset Service Providers.
- Unregulated Forex or CFD;
- Unlicensed investment and financial services.
- Non-fungible token (NFT)
- Collection of donations as a charity or non-profit organization, NGO’s (unregulated, unregistered and incorporated outside EU);
- Unregulated pharmaceuticals, and or unlicensed drug related activity;
- Oil & Gas Industries (extraction, distribution);
- Activities relate to the sale of dangerous or hazardous goods;
- Replicas;
- ‘Adult services, escort
- Online dating sites;
- Unlicensed gambling, gaming, casino, betting or related services;
- Customers engaging in alcohol and tobacco trade (including online sale);
- Weapons, firearms and ammunitions (production, distribution);
- Customers engaged in drug sale such as marijuana or other illegal substances;
- Religious Organizations and NPOs;
- Extractive industries such as extraction of precious stones and minerals;
- Art and Antiques;

Monitoring.

An element of a Payhof AML Policy in which client activity is reviewed for unusual or suspicious patterns, trends or outlying transactions that do not fit a normal pattern. Transactions are often monitored using software that weighs the activity against a threshold of what is deemed “normal and expected” for any given client. Payhof will rely on internal anti-money laundering system and controls. Monitoring is done automatically and manually by receiving alerts generated by the internal rules-based monitoring system.

Internal controls.

Policies, procedures, systems and personnel within Payhof, are structured to protect against the materialisation of a ML risk, or to ensure that risk factors are promptly identified.

Unacceptable Levels of Risk.

Payhof will not knowingly conduct business with anyone who has engaged in any criminal activities. Further, Payhof will not enter into a business relationship with prohibited parties which include:

Not Acceptable Countries

Afghanistan

Albania

American Samoa

Barbados

Belarus

Burkina Faso

Burundi

Cambodia

Cayman Islands

Central African Republic

Chad

Comoros

Congo

Crimea

Cuba

Democratic Republic of Congo

DPRK

Equatorial Guinea

Eritrea

Fiji

Gibraltar

Guam

Guatemala

Guinea

Guinea Bissau

Haiti

Honduras

Iran

Iraq

Jamaica

Jordan

Lebanon

Libya

Mali

Morocco

Myanmar

Nicaragua

Nigeria

Pakistan

Palau

Palestine

Panama

Philippines

Russia

Samoa

Senegal

Somalia

South Sudan

Sudan

Syria

Tajikistan

Trinidad and Tobago

Turkey

Turkmenistan

Uganda

United Arab Emirates

US Virgin Islands

USA

Vanuatu

Venezuela

Yemen

Zimbabwe

...

    Destination of funds

    In accordance with Payhof country risk rating methodology, we will not process transactions from/to the following countries:

    Afghanistan

    Belarus

    Central African Respublic

    Cuba

    Democratic Republic of Congo

    DPRK

    Iran

    Iraq

    Lebanon

    Libya

    Mali

    Nigeria

    Russia

    Somalia

    Syria

    Crimea

    Luhanks and Donetsk regions

    Yemen


 

Sources:

European Commission; European Parliament and the Council - list of high-risk third countries with strategic deficiencies.

Consolidated List of European Union Financial Sanctions (EU sanction map).

The Financial Action Task Force (FATF)-list of jurisdictions with strategic AML/CFT deficiencies.

https://www.fatf-gafi.org/countries/d-i/democraticpeoplesrepublicofkoreadprk/documents/call-for-action-march-2022.html

https://www.knowyourcountry.com/country-ratings-table

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