Blacklisted Jurisdictions and AML Risk Appetite Statement
Address: Žalgirio g. 90-100, LT-09303 Vilnius
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.
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.
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.
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
- Collection of donations as a charity or non-profit organization, NGO’s (unregulated and incorporated outside EU)
- Selling of Drugs including online sale
- Extractive Industries
- Unregulated pharmaceuticals, and or unlicensed drug related activity
- Oil & Gas Industries (extraction, distribution)
- Activities relate to the sale of dangerous or hazardous goods
- Adult products, 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)
- Religious Organizations and NPOs
- Extraction of precious stones and minerals
- Art and Antiques
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.
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.
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:
Democratic Republic of Congo
Trinidad and Tobago
US Virgin Islands
United Arab Emirates
Luhanks and Donetsk
In accordance with Payhof country risk rating methodology, we will not process transactions from/to the following countries:
Central African Respublic
Democratic Republic of Congo
Luhanks and Donetsk regions
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.