AML Policy

3. Know Your Customer (KYC)

FinQard operates customer identification and verification procedures designed to establish the identity of customers and reduce fraud and financial-crime risks.

FinQard may use third-party identity verification and compliance service providers to validate information supplied by customers.

Customers must provide accurate, complete and current information. Providing false, misleading, fraudulent or materially incomplete information may result in a transaction being declined or an account being restricted, suspended or terminated.

4. Customer Due Diligence

FinQard applies Customer Due Diligence (“CDD”) measures based on the nature and level of risk associated with a customer, product or transaction.

Due diligence may be conducted when an account is created, before certain services are activated, when transactions occur, periodically during the customer relationship or whenever FinQard identifies a material change in risk.

5. Enhanced Due Diligence

FinQard may apply Enhanced Due Diligence (“EDD”) where a customer or activity presents a higher level of financial-crime risk.

This may occur in circumstances involving unusually large or frequent transactions, complex or inconsistent transaction patterns, high-risk jurisdictions, politically exposed persons where applicable, sanctions exposure, identity inconsistencies, suspected account compromise, unusual cryptocurrency, gift card or virtual card activity, suspected third-party transactions, transactions without an apparent legitimate purpose, or other circumstances indicating elevated risk.

FinQard may request additional identification, proof of address, source-of-funds information, transaction documentation or other supporting evidence before allowing a transaction or account activity to proceed.

6. Transaction Monitoring

FinQard may monitor transactions and account activity to identify suspicious, unusual, fraudulent or potentially unlawful behaviour.

Monitoring may include analysis of transaction amounts, frequency and velocity; transaction history; payment sources and destinations; bank account information; cryptocurrency deposits and withdrawals; blockchain wallet addresses; gift card transactions; virtual card funding and spending; merchant activity; bill payments; account access; devices and IP information; attempted or failed transactions; reversals and refunds; chargebacks; account behaviour; and other relevant risk indicators.

FinQard may use automated systems, manual reviews or a combination of both. Transactions may be delayed, declined, restricted or subjected to additional verification where necessary.

7. Cryptocurrency and Blockchain Transactions

Cryptocurrency transactions may present additional financial-crime, sanctions and fraud risks.

Where appropriate, FinQard and its service providers may analyse cryptocurrency wallet addresses and blockchain transactions for exposure to stolen digital assets, scams, fraud, ransomware, darknet markets, sanctioned persons or entities, terrorist financing, money laundering, illicit services and other unlawful activity.

FinQard may reject, delay or investigate a cryptocurrency transaction where its risk controls identify potentially prohibited or suspicious activity.

Customers are responsible for ensuring that they use the correct wallet address and blockchain network when conducting cryptocurrency transactions.

8. Gift Card Transactions

Customers may only sell or otherwise transact with gift cards that they lawfully own or are legally authorised to use.

FinQard prohibits gift cards obtained through theft, fraud, scams, identity theft, unauthorised account access, stolen payment instruments, social engineering, payment fraud or any other unlawful activity.

FinQard may review gift card information, transaction patterns and supporting evidence to assess authenticity, ownership and financial-crime risk. Where necessary, FinQard may request receipts, proof of purchase or other information relating to the origin or ownership of a gift card.

9. Virtual Cards

Where FinQard provides access to virtual cards, such services may be provided through third-party financial institutions, card issuers, processors or payment partners.

FinQard may monitor virtual card activity for fraud, money laundering and other prohibited activities, including card funding, transaction amounts and frequency, merchants and merchant categories, transaction locations, unusual spending patterns, declined transactions, reversals, refunds and chargebacks.

Customers must not use FinQard virtual cards for unlawful activities or transactions prohibited by FinQard, the relevant card issuer, payment network, processing partner or applicable law.

FinQard or its relevant service provider may restrict, freeze or terminate a virtual card where suspicious, fraudulent or prohibited activity is identified.

10. Payments, Wallets, and Bill Payments

FinQard may monitor wallet funding, withdrawals, transfers, payouts and bill-payment transactions for unusual or suspicious activity.

We may request additional verification where payment information does not match verified customer information, a transaction appears to involve an unidentified third party, unusual funding patterns are detected, transactions significantly differ from normal customer activity, or additional verification is required by FinQard or one of its service providers.

11. Sanctions Screening

Where appropriate or required, FinQard may screen customers, counterparties, transactions and wallet addresses against applicable sanctions lists, watchlists and financial-crime databases.

FinQard may decline to establish or continue a customer relationship or may restrict a transaction where doing so is necessary to comply with applicable law, sanctions requirements or FinQard's risk policies.

12. Suspicious Activity

Where FinQard reasonably suspects money laundering, terrorist financing, proliferation financing, fraud or other unlawful activity, we may request additional information, conduct enhanced verification, delay or decline transactions, restrict account functions, suspend or terminate accounts, preserve records, and make disclosures or reports to competent authorities where legally required or permitted.

Where prohibited by law, FinQard may not disclose to the affected customer that a suspicious activity report, investigation or related regulatory disclosure has been made.

13. Prohibited Activities

FinQard must not be used to launder proceeds of crime; finance terrorism or proliferation activities; conduct or facilitate fraud; transact with stolen assets; sell stolen or fraudulently obtained gift cards; disguise the source, ownership or destination of funds; circumvent sanctions; operate an account using a false identity; use another person's account without authorisation; facilitate scams; conduct prohibited virtual card transactions; conceal beneficial ownership where disclosure is required; evade transaction limits or compliance controls; or conduct any activity prohibited by applicable law.

14. Account Restrictions

FinQard reserves the right, subject to applicable law and contractual obligations, to restrict, suspend or terminate an account or service where KYC requirements have not been satisfied, information supplied is false or materially misleading, suspicious or fraudulent activity is detected, requested compliance information is not provided, an account appears compromised, FinQard is required to act by law or competent authority, a service provider requires the restriction, FinQard's services are being abused, or continued provision of services presents unacceptable financial-crime, regulatory, security or fraud risk.

15. Record Keeping

FinQard may retain appropriate customer identification, verification, transaction and compliance records for periods required by applicable law and legitimate regulatory, fraud-prevention, dispute-resolution and compliance purposes.

16. Cooperation with Authorities

FinQard may cooperate with courts, regulators, law enforcement agencies and other competent authorities where required or permitted by applicable law, including responding to valid requests, court orders, investigations and statutory reporting requirements.

17. Risk-Based Approach

FinQard applies a risk-based approach to financial-crime prevention. Different customers, products, transaction types, payment methods, geographical locations and delivery channels may present different levels of risk.

Accordingly, verification requirements, transaction limits, monitoring measures and restrictions may vary depending on the circumstances.

18. Employee and Internal Controls

FinQard maintains internal controls designed to support its AML/CFT/CPF programme. Where applicable, these may include designated compliance responsibilities, employee training, access controls, transaction monitoring, escalation procedures, record keeping, internal reviews and periodic assessment of financial-crime risks.

19. Policy Review

FinQard may periodically review and update this AML Policy to reflect changes in applicable law, regulatory expectations, FinQard's products, technology and financial-crime risks.