Introduction
Paypaid is committed to the highest standards of Anti-Money Laundering (AML) and AntiFinancial Crime (AFC) The Management Board and all employees are required to adhere to these standards to protect Paypaid and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.
Paypaid has its headquarters in Bangkok, Thailand and is supervised by BOT (Bank of Thailand).
Paypaid will adhere to all applicable laws and regulations in all countries where it conducts business, or has business relationships to.
Paypaid will examine its AML and AFC strategies, goals and objectives on an ongoing basis and maintain an effective program for the Bank’s business that reflects the best practices for a diversified, global financial payment services provider.
The program addresses all AML-related topics, especially Know Your Customer (KYC), ABC and Anti-Fraud.
For all these topics Paypaid has implemented clear rules and regulations which must be complied with by all Paypaid staff.
Prohibited business relationship
PAYPAID must refuse to open a merchant account/enter into a relationship or has to close an existing merchant account/terminate a relationship, if the Paypaid cannot form a reasonable belief that it knows the true identity of the client and/or UBOs and/or the nature of business or formal requirements concerning the identification of the client and/or UBOs are not met. In particular, Paypaid will not
• Accept assets that are known or suspected to be the proceeds of criminal activity
• Enter into/maintain business relationships with individuals or entities known or suspected to be
• a terrorist or a criminal organisation or member of such or listed on sanction lists
• Maintain anonymous accounts, accounts for shell Paypaids or pay-through accounts
• Enter into relationships with clients from Special Risk Countries or
• Enter into relationships with clients operating in prohibited industries
Research and Filing of Suspicious Activity Reports (SARs)/Suspicious Transaction Reports (STRs)
Suspicious activities must be properly handled and escalated within the respective PAYPAID legal entity Regular AML training ensures that staff are reminded of their duty to timely report any suspicious activity to their respective AML Officer, where allowed under local regulations.
Management and Controls of AML and AFC Risk
PAYPAID has developed and implemented a comprehensive set of measures to identify, manage and control its AML risk. These measures are
• AML / AFC Risk Analysis
• Controls
• A robust and strict KYC program
• Special safeguards for correspondent Paypaids relationships
• training and awareness program for PAYPAID staff
• Processes to ensure staff reliability
Risk Analysis
Risk Analysis to assess the level of risk exposure considering Paypaids customers, products, services, entities and geographic locations risk and to derive appropriate security measures from this analysis. AML safeguards are derived from the results of the AML Risk Analysis.
Controls
Adherence to the AML/AFC program needs to be reviewed regularly to ensure that Paypaid’s efforts are successful. AML Officers in PAYPAID are therefore obliged to conduct appropriate Anti- Financial Crime, Anti-Money Laundering Statement reports to Bank of Thailand (BOT)
The responsible AML Officer must ensure, by implementing adequate customer- and business related controls that all applicable AML and AFC requirements are being adhered to and security measures are properly functioning.
KYC
PAYPAID has implemented a strict KYC program to ensure all kinds of customers (natural or legal persons or legal structures) are subject to adequate identification, risk rating and monitoring measures.
KYC includes not only knowing the clients and entities Paypaid deals with (either as a single transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial Owners (UBOs), Legal Representatives and Authorised Signatories as appropriate. KYC includes strict identification requirements, name screening procedures and the ongoing monitoring and regular review of all existing business relationships.
Training Program
PAYPAID has implemented a comprehensive AML/AFC training program to ensure that all staff, in particular individuals responsible for transaction processing and/or initiating and/or establishing business relationships, undergo AML awareness training.
Paypaid’s training is tailored to the business to ensure that staff are aware of different possible patterns and techniques of money laundering which may occur in their everyday business. Training also covers the general duties arising from applicable external (legal and regulatory), internal requirements and the resulting individual duties which must be adhered to in everyday business as well as typologies to recognize money laundering or financial crime activities.
Reliability of Staff
PAYPAID has implemented processes to ensure that only reliable individuals are employed.
Record Retention
All data obtained according to client identification and AML security measures must be documented. Records must be kept for a minimum of 5 years, notwithstanding potentially longer retention periods under local civil or commercial law.
Independent Testing
Adherence to the requirements of PAYPAID’s AML program is subject to independent testing by BOT, PAYPAID’s Internal Audit function and the Annual External Year-End Auditor
