KYT/AML Policy

Global PayTech Know Your Transaction (KYT) & Anti-Money Laundering (AML) Policy

1. Introduction Global PayTech is committed to maintaining the highest standards of compliance with international anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. This Know Your Transaction (KYT) and AML policy outlines the company’s approach to preventing illicit financial activities, ensuring compliance with legal requirements, and protecting our customers and partners.




2. Regulatory Compliance Global PayTech adheres to AML and CTF regulations set forth by international regulatory bodies, including but not limited to:

• The Financial Action Task Force (FATF)
• The European Union’s AML Directives
• The U.S. Bank Secrecy Act (BSA)
• Local regulations applicable in jurisdictions where we operate

3. Know Your Transaction (KYT) Policy KYT is an essential part of our transaction monitoring framework to detect suspicious activities. Key components include:

• Transaction Monitoring: Continuous tracking of transactions to identify unusual patterns.
• Risk-Based Approach: Assigning risk scores to transactions based on multiple factors such as amount, frequency, geographical location, and parties involved.
• Red Flags & Alerts: Identifying potentially suspicious transactions, such as high-value transactions without a clear economic purpose, frequent cross-border transfers, and structuring (smurfing) activities.
• Enhanced Due Diligence (EDD): Additional scrutiny for high-risk transactions, including verification of source of funds.

4. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

• Customer Identification Program (CIP): Mandatory verification of customers before initiating transactions.
• Risk Profiling: Classifying customers into low, medium, or high-risk categories based on their profile and transaction behavior.
• EDD Measures: For high-risk clients, additional documentation and ongoing monitoring are required.

5. Suspicious Activity Reporting (SAR) Global PayTech ensures prompt reporting of suspicious transactions to relevant regulatory bodies. Our SAR process includes:

• Identifying unusual patterns that may indicate money laundering, fraud, or terrorist financing.
• Escalating cases internally for review by the compliance team.
• Filing reports with Financial Intelligence Units (FIUs) when necessary.

6. Sanctions Screening & Politically Exposed Persons (PEP) Checks

• Sanctions Screening: Regular checks against global sanction lists such as OFAC, UN, and EU lists.
• PEP Identification: Identifying and monitoring transactions involving politically exposed persons and their close associates.

7. Record Keeping All AML and KYT-related records, including customer data, transaction logs, and reports, are maintained for at least five years in compliance with regulatory requirements.
8. Training & Awareness Global PayTech provides regular AML and KYT training to employees to ensure awareness and compliance with evolving regulations.
9. Compliance & Internal Controls

• The company has a dedicated AML Compliance Officer responsible for implementing and enforcing this policy.
• Regular internal audits are conducted to ensure compliance with AML and KYT procedures.

10. Conclusion Global PayTech remains committed to maintaining a robust AML and KYT framework to combat financial crimes effectively. This policy is reviewed and updated regularly to align with regulatory changes and industry best practices.

For any compliance-related inquiries, please contact our AML Compliance Team at [email protected]