AML/KYC Policy
PSP PRO Anti-Money Laundering And Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of PSP PRO being involved in any kind of illegal activity.
Both international and local regulations require PSP PRO to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery and to take action in case of any form of suspicious activity from its Users.
AML/KYC Policy covers the following matters:
- Verification procedures.
- Monitoring Transactions.
- Risk Assessment.
- Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, PSP PRO establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
Identity verification
PSP PRO’s identity verification procedure requires the User to provide PSP PRO with reliable, independent source documents, data, or information (e.g., national ID, passport, bank statement, utility bill). For such purposes Services reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
PSP PRO will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and PSP PRO reserves the right to investigate certain Users who have been determined to be risky or suspicious.
PSP PRO reserves the right to verify User’s identity on an on-going basis, especially when their identification information has been changed or their activity seems to be suspicious (unusual for the particular User). In addition, PSP PRO reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared, and protected strictly in accordance with the PSP PRO’s Privacy Policy and related regulations.
Once the User’s identity has been verified, PSP PRO is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
Card verification
The Users who intend to use payment cards in connection with the PSP PRO’s Services have to pass card verification in accordance with instructions available on the PSP PRO’s Site.
What is your personal data used for?
Log Data, which is collected via our IT infrastructure for our corporate website, www.psppro.com, and which includes the IP (Internet Protocol) address and geographical location, as well as the internet access service provider of an individual visitor, information of the type of computer or telecommunication device used to enter our corporate website, information on the data accessed, the duration and frequency of sessions and the page visit history is used for internal statistical purpose only and neither retained, nor disclosed to any third party.
Contact data, including an individual’s name, surname, electronic mail address and any other personal information communicated to PSP PRO via our chat function on our corporate website, as well as via the contact form in the ‘contact-us’-section of our corporate website, is used only for establishing a proper communication channel with the specific data subject. This data is stored and retained in accordance with the applicable legislation and neither disclosed to any third party, nor accessible to any unauthorized personnel or third party.
All data collected by PSP PRO, which relates to our prospective and / or existing client (including individuals as well as representative/s, UBO/s and / or local management of corporate clients) is used for rendering our services to our clients.
Personal data related to a specific individual data subject is used to send commercial and non-commercial notifications of PSP PRO to that data subject.
How is your personal data stored and/or retained?
PSP PRO will only use, store, process and handle the client’s Personal Information and Data, in accordance Data Protection regulation 679/2016/EU.
This means we retain hard copies of personal data related to individual persons (individual visitors of our corporate website, private clients and/or representative/s or UBO/s of corporate clients) in protected storage facilities, to which unauthorized persons do not have any access.
We retain electronic soft copies of personal data related to individual persons (individual visitors of our corporate website, private clients and/or representative/s or UBO/s of corporate clients) in protected and encrypted IT facilities, free from unauthorized access.
All communication in which individuals share their personal data with PSP PRO, the communication channel is protected by an SSL secure log protocol technology.
Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analysis of their transactional patterns (what they do). Therefore, PSP PRO relies on data analysis as a risk-assessment and suspicion detection tool. PSP PRO performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
Daily check of Users against recognized “blacklists” (e.g., OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications, and filling out statutory reports, if applicable, Case and document management.
With regard to the AML/KYC Policy, PSP PRO will monitor all transactions, and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement.
- request the User to provide any additional information and documents in case of suspicious transactions;
- suspend or terminate User’s Account when PSP PRO has reasonable suspicion that such User engaged in illegal activity.
The above list is not exhaustive, and PSP PRO will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
Risk Assessment
PSP PRO, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, PSP PRO is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
Enhanced Due Diligence Procedures for High-Risk Customers
Enhanced Due diligence is a KYC process that provides a greater level of scrutiny of potential business partnerships and highlights risk that cannot be detected by Customer Due Diligence. Risk Management procedures often differentiate based on a customer’s risk profile. It starts by taking steps to ensure you know who you are dealing with, understanding their activities, and assessing their risk of money laundering. Determining if a potential account requires enhanced due diligence (EDD) includes:
- Location of the business
- Occupation or nature of business
- Purpose of the business transactions
- Expected pattern of activity in terms of transaction types, dollar volume, and frequency
- Expected origination of payments and method of payment
- Articles of incorporation, partnership agreements and business certificates
- Understanding of the customer’s customers
- Identification of beneficial owners of an account or customer
- Details of other personal and business relationships the customer maintains
- Approximate salary or annual sales
- AML policies and procedures in place
- Third-party documentation
- Local market reputation through review of media sources
Some EDD practical steps include:
- Location of the business
- Obtaining additional identifying information from a wider variety or more robust sources and using the information to inform the individual customer risk assessment.
- Carrying out additional searches (e.g., verifiable adverse media searches) to inform the individual customer risk assessment.
- Commissioning an intelligence report on the customer or beneficial owner to understand better the risk that the customer or beneficial owner may be involved in criminal activity.
- Verifying the source of funds or wealth involved in the business relationship to be satisfied that they do not constitute the proceeds from crime.
- Seeking additional information from the customer about the purpose and intended nature of the business relationship.
Governing Law and Venue
These Terms and Conditions shall be governed by and construed in accordance with UK law. Disputes arising in connection with these Terms and Conditions shall be subject to the exclusive jurisdiction of the UK courts.
