How we prevent financial crime.

01Purpose and scope

This policy sets out the controls RimonPay applies to prevent its services being used for money laundering, terrorist financing, sanctions evasion or other financial crime. It applies to all personnel, contractors and partners acting for RimonPay, and to every enquiry, application and document set we handle.

02Policy statement

RimonPay has zero tolerance for financial crime. We will not knowingly act on a file that we believe involves criminal property, terrorist financing, sanctions evasion or the proceeds of crime. Where we suspect financial crime, we will stop work on the file, make the appropriate report, and keep no record of that report visible to the person concerned.

03Governance and responsibility

04Risk-based approach

We assess the money laundering and terrorist financing risk of each file, and apply controls proportionate to that risk. Our assessment considers:

• Customer risk — entity type, ownership structure, trading history, and whether the business is newly formed;
• Product and sector risk — the industry and business model, including sectors acquirers treat as higher risk, and any high-value or unusual transaction profile;
• Geographic risk — the countries the business operates in or from, its owners’ locations, and any nexus to high-risk or sanctioned jurisdictions;
• Delivery channel risk — how the business sells and takes payment, including the share of card-not-present transactions.

05Know your business and customer due diligence

Before we introduce a file, we establish and verify the following:

• The business — legal name, entity type, registration number, country and date of incorporation, registered address and trading address.
• Ownership and control — every director, and every beneficial owner holding 25% or more, identified by name, date of birth, nationality, residential address and ownership percentage. Where no individual meets the threshold, we identify the senior managing official.
• Identity — photo identification for each director and beneficial owner, and proof of their residential address.
• The business itself — what it sells, to whom, how, and how it takes payment; plus its website and, where it already accepts cards, its processing history.
• The settlement account — account holder name, bank, IBAN or account number, and confirmation that the account belongs to the business.

We use the documents and information collected through the application for this purpose, together with registry checks and independent verification where necessary. We do not proceed where we cannot establish ownership or verify identity to a satisfactory standard.

06Sanctions screening

We screen the business, its directors and its beneficial owners against applicable sanctions lists before introducing a file, and again if we become aware of a change. [Insert the lists you screen against — for example the UK OFSI consolidated list, the EU consolidated list, the UN Security Council list and the US OFAC list.]

We do not act on files connected to territories subject to sanctions, or involving a sanctioned person or entity, or a person or entity owned or controlled by one. Where we identify a potential match, we investigate before taking any action, and we do not proceed while a match is unresolved.

07Politically exposed persons and adverse media

We screen directors and beneficial owners to identify politically exposed persons and their close associates and family members, and we check for credible adverse media relating to financial crime. Where a person is identified as politically exposed, we apply enhanced measures: senior approval before proceeding, establishing the source of wealth and source of funds, and more frequent review.

08Enhanced due diligence and high-risk indicators

We apply enhanced measures where risk is higher. Indicators that trigger closer scrutiny include: complex or opaque ownership structures; nominee shareholders; ownership in a high-risk jurisdiction; a business with no trading history; an unexplained mismatch between the business described and the volumes expected; frequent changes of provider; high chargeback or refund levels; and reluctance to provide documents or explain the business model.

Where enhanced measures cannot resolve our concerns, we decline to act on the file.

09Relying on regulated partners

Acquirers are regulated firms with their own customer due diligence obligations. Where we introduce a file, we provide accurate and complete information so the acquirer can meet those obligations, and we cooperate fully with the acquirer’s own compliance and underwriting enquiries. We do not withhold information from an acquirer, and we do not present a file in a way that understates its risk.

10Information sharing and authorisation

This authorisation is set out in full in our Terms of Use and is reflected in the declaration the applicant accepts before submitting.

11Record keeping

We keep records of the checks we carry out, the documents we rely on, and the decisions we take, for as long as is necessary and in any event for the retention period required by applicable law. Where the Money Laundering Regulations apply, that period is five years from the end of the business relationship. Records are kept securely and are available to the acquirer, and to regulators or law enforcement on lawful request.

12Reporting suspicions

• Anyone who suspects money laundering, terrorist financing or sanctions evasion must report it immediately to the compliance lead.
• Where a report is required, it is made to the National Crime Agency by the nominated officer, without delay.
• No one may tip off the person concerned that a report has been made or is being considered. This is a criminal offence.
• Where a suspicious activity report is made and consent is required, we do not proceed with the file until consent is received or the relevant period expires.
• We do not discriminate or retaliate against anyone who reports a concern in good faith.

13Training and awareness

All personnel receive financial crime training on joining and at least annually thereafter, covering our obligations, the risk factors and red flags, how to escalate, and the prohibition on tipping off. Completion is recorded. Additional training is provided whenever the law or our risk assessment changes.

14Monitoring and review

Compliance with this policy is monitored by the compliance lead, who reports to senior management at least annually. This policy and our risk assessment are reviewed at least annually, and whenever there is a material change in the law, our business, or the risks we face.

15Approval and contact

This policy is approved by senior management of RimonPay. Concerns or questions should go to the compliance lead at sales@rimonpay.com.