Transactworld Ltd. ("Transactworld" and / or the Company")is faced with the risk that someone may use the Company's system to commit financial fraud ,launder money or finance terrorism.In order to control these risks,the Company has implemented robust Anti-Money Laundering ("AML") and Counter Terrorist Financing("CTF") policies and procedures aimed at preventing money laundering ,financing criminal activities and terrorist financing attempts to ensure compliance with applicable AML Laws and regulations.
Know Your Customer(KYC)
Know Your Customer Procedure ("KYC") have becoming increasingly important globally to prevent financial fraud,money laundering and terrorist financing.KYC procedures are at the heart of the due diligence obligations of all financial institutions and will be applied before accepting a customer , and throughout the time that customer is under their responsibility. A rigorous KYC program is the due diligence that the Company performs to identify prospective Clients, and evaluate relevant information pertinent prior to doing business with them. It can be summarized as the process of 'Clients identification and vertification' to be able to assess the risks that merchant relationship constitutes at its commencement and for its duration.
Client Due Diligence
The Company's Clients which provide goods and services, and intend to use Transactworld as a payment mechansism or open an account (IBAN), are provided an electronic wallet. This Wallet is exclusive to each Client and allows to receive funds or to send funds to client's partner's accounts.
The Company will establish relationships with Clients operating in a wide range of industries, mainly targeting low margin merchants (with a commensurate lower financial and/or reputational risk) ranging from retail, financial services, telecommunications to ticketing, portals ,digital content and publishing. A less significant number of Transactworld's clients will be represented by companies in the high margin industry such as Software/mp3 download pharmacy (non-controlled drugs ) and Nutraceuticals /diet control substances , adult, and travel.Transactworld realizes that clients due diligence is one of, if one the most critical steps in ensuring that their portfolio of clients operate within the company's rules and regulations, the payment card organizations rules ,regulations and parameters and are profitable for the Company .To implement this understanding, The Company performs a rigorous risk assessment, a very aggressive pre-acceptance process and then, after acceptance and boarding ,performs constant transaction and business practices monitoring to ensure that all of the Company's goals and expectations for a clients are met.
As per of its fraud detection and prevention mechanisms the Company will first perform a rules based assessment of each prospective Clients.
The Company will perform checks against any sanctions lists published by relevant governmental or regulatory authority. Particular reference will be made to countries where the Financial Action Task Force (hereinafter "FATF"), The office of foreign Assests Control (hereinafter "OFAC") have identified systmatic deficiencies in systems to prevent money laundering and terrorist finance.
Each Owner of the prospective Client will be also checked against politically Exposed Person's list (hereinafter "PEPs").
"The company will then perform a series of risk based evaluations to determine".
- .if the prospective client is viable ; and
- . if viable, assign values to transaction-number-allowed-by-period and economic-value-allowed-by-period.
Some , but not all of the factors taken into consideration to achieve the aforementioned risk assessments and value assignments are:
The type of Relationship:
- In a bussiness relationship
- Occasional customers
- One off customers
- The Type of product and /or service risk
The risk score is assigned based on the type of product/service offered by the clients. Merchants offering banned product/service will be excluded from the business.
- The Clients business type
The risk score is assigned based on the type of business the merchant in operating .High margin merchants, included in the following borderline industries, will be subject to enhanced due diligence and monitoring:
- E Commerce
- Money Remittance
- Crypto Currency
- Other Risks
Risk and Compliance department will be responsible for assessing each prospective clients based on these risk factors. The factors taken into consideration are updated regularly to reflect current risk pattern, information developed as a result of doing business, information received from the card organizations and the acquiring banks that developed from the public domain.
The Company evaluate all submitted documentation to ensure that its current and valid .In addition Transactworld performs a number of addition checks such as searching the internet for information on the prospective Clients and its directors ,owners and management,searching relevant social media ,performing a comprehensive review of the website including utilizing web crawler to ensure that is no prohibited verbiage or content on the clients website , using specialized risk management companies such as G2 to check provided information and then perform subsquent monthly monitoring , and when possible utilizing the opportunity to check the Card Organization ' MATCH and NMAS Lists.
The Company performs a site of all prospective clients. The site Visit may be by Transactworld management ,appropriate staff or through use of an agent in the prospective merchant's physical location.Transactworld also performs periodic re-visits of all boarded clients physical sites.
In addition , a site visit to the fulfilment faciliaties of any prospective client who sells products which must be delivered to its customers is performed.These site visits are performed by company management or appropriate staff it is access geographical location .In that case ,these site visits are performed by qualified and contracted agents.
Enhanced Due Diligence
For business relationship, clients and transaction, Transactworld must apply enhanced due diligence measures. Some categories of business relationships are as fellows.
- Politically Exposed Persons
- Sanction lists
- The Office of Foreign Assets control ("OPAC")
- The Financial Action Task Force(FATF")
- The Financial Sanctions Unit of the Bank of Cyprus
Each Owner of the prospective clients is checked against PEPs list .Decisions to enter into such business relationships should be taken with the concurrence of senior management.
All prospective clients and any Beneficial Owner and Officer and any management individual with significant control over the operations and finances of the prospective client (hereinafter the "Owner") will be checked against the sanction lists (hereinafter the "lists) released by the fowllowing bodies:
Any Owner identified on the List will be subjected to futher due diligence to ascertain if the individual is the one on the List.Any Owner on the List will result in the prospective Clients being rejected.
Same is applicable to the situation if the client is situated in a country which is included in the Financial Action Task Force(FATF) non cooperative countries and territories list.
The Company understands that the Lists are updated on a periods basis and will thus check all Clients and their Owner periodically to see if any have been added. Any Clients or Owner Discovered to have seen added to the lists will immediately be terminated.
After a clients has been approved and brought on boarded , the Company performs a comprehensive process of transaction monitoring to ensure complete compliance with agreed terms and conditions ,as specified in the Agreement.
The Company has developed and Utilized an internally developed and maintained state-of-the-art automated fraud preventing and risk management system. This system leverages the extensive business experience of the Company's management and fraud staff.The system is a "Rules Based" system. Apart from that, at any point of time Transactworld can ask for the information regarding any transaction carried out through the clients account and the parties related to this transaction.
The company also uses number of comerically available comprehensive anti-fraud and risk mitigration tools companies and professional organizations including ,but not limited to:
- G2 LLC
- AVS checks
In the addition to the above described automated processes,Transactworld performs a periodic re-underwriting of each clients.This re-underwriting process can be triggered simply by the passage of time , by any of the key transaction monitoring events described above by any change in management or ownership of the Clients or by any external information to which the Company has access that might raise risk related red-flags.At minimum all the Clients are re-underwritten annually.
This post-transaction analysis, performed on the entire database of transaction ,is aimed at detecting fraud trends .It is designed to identify any potential criminal collusion or activities that might require terminating a clients and reporting their activty to relevant government and /or law enforcement regulators and /or authorities .
List of Banned Products and Services
- Escort or prostitution Services: website access and website memberships of Escort or prostitution sites.
- Alcohol: - which includes alcohol or alcoholic beverages such as beer, liquor, wine, or champagne.
- Body parts: - which includes organs or other body parts.
- Bulk marketing tools: - which includes email lists, software, or other Products enabling unsolicited email messages (i.e. Spam)
- Cable descramblers and black boxes: - which includes devices intended to obtain cable and satellite signals for free
- Child pornography: - which includes pornographic materials involving minors.
- Copyright unlocking devices: - which includes Mod-chips or other devices designed to circumvent copyright protection
- Copyrighted media: - which includes unauthorized copies of books, music, movies, and other licensed or protected materials.
- Copyrighted software: - which includes unauthorized copies of software or protected materials, including OEM or bundled software.
- Counterfeit and unauthorized goods: - which includes replicas or imitations of designer goods; items without a celebrity endorsement that would normally require such an association; fake autographs, counterfeit stamps, and other potentially unauthorized goods.
- Drugs and drug paraphernalia: - which include illegal drugs and drug accessories, including herbal drugs like salvia and magic mushrooms.
- Drug test circumvention aids: - which includes drug cleansing materials, urine test additives, and related items.
- Endangered species: - which includes plants, animals or other organisms (including Product derivatives) in danger of extinction.
- Government IDs or documents: - which includes fake IDs, passports, diplomas, and noble titles.
- Hacking and cracking materials: - which include manuals, how-to guides, information, or equipment enabling illegal access to software, servers, websites, or other protected property.
- Illegal goods: - which includes materials, Products, or information promoting illegal goods or facilitating illegal acts.
- Offensive goods: - which includes literature, products, or other materials that:
- Defame or slander any person or groups of people based on race, caste, ethnicity/colour, national origin, religion, sex, political opinions or other factors
- Encourage or incite violent acts.
- Promote intolerance or hatred.
- May incite crime, which includes crime scene photos, or items such as personal belongings associated with criminals.
- Drugs requiring prescription from online pharmacies: - which includes drugs or other Products requiring prescription by a licensed medical practitioner.
- Pyrotechnic devices, combustibles, corrosives and hazardous materials: - which includes explosives, fireworks and related goods; toxic, flammable, and radioactive materials and substances.
- Regulated goods: - which includes air bags; batteries containing Mercury; Freon or similar refrigerants; chemical and industrial solvents; government uniforms; car titles; license plates; police badges and law enforcement equipment; lock-picking devices; pesticides; postage meters; recalled items, slot machines; surveillance equipment; and Products and Services regulated by governments or regulatory agencies.
- Tobacco and cigarettes: - which includes cigarettes, cigars, chewing tobacco, and related Products.
- Traffic devices: - which includes radar detectors, jammers, license plate covers, traffic signal changers, and related Products.
- Weapons: - which includes firearms, ammunition, knives, brass knuckles, gun parts, and other armaments.
- Live animals or hides, skins, teeth, nails and other parts of animals.
- Multi-level marketing and network marketing collection fees.
- Matrix sites or sites using a matrix scheme approach.
- Work-at-home approach and work-at-home information.
- Drop-shipped merchandise.
- Any Product or Service that is not in compliance with all applicable laws and regulations whether federal, state, local or international including the laws of Cyprus.
- Products and Services that have the potential of casting Transactworld in a poor light and that may be prone to foster a "Buy & Deny" attitude of the Customers when billed (e.g. adult material, mature content, escort services and other adult services such as adult dating and adult friend finders).
- Products and Services outrightly banned by law (e.g. betting and publications or content that is likely to be interpreted by the authorities as leading to moral turpitude or decadence, or incite caste/communal tensions, lotteries, sweepstakes.
- Intangible Products and Services (e.g. software downloads, self help and education materials)
- Pyramid marketing schemes or any type of get-rich-quick schemes.
- Web-based telephony, SMS, text, facsimile services or calling cards, bandwidth or data transfer or allied Services.
- Voice process, knowledge process services.
- Mailing lists.
- Any other Product or Service, which in the sole opinion of Transactworld is detrimental to the image and interests of the Company, as communicated by it to the Client from time to time.
if you have any question regarding our AML Policy please contact us at: email@example.com