AML Policy

Last updated on 01 October 2019

MPT PAY AML Risk Appetite Statement provides the framework through which the Business describes the level and types of AML risk that MPT PAY is willing to incur in executing its broader business strategy.
AML Risk ProfileMPT PAY AML Risk Profile is composed of products and services, customers (individuals and entities) and country risk. Within these risk categories and as a result of the global reach in providing a service MPT PAY could be unwittingly used for the furtherance of financial crime. Financial crime – MPT PAY must comply with legal requirements to deter and detect financial crime, which includes money laundering and terrorist financing.Products and services. MPT PAY focuses on B2B services offering e-wallet and bank wire options (SEPA/SWIFT). In Q4 MPT PAY will be offering debit cards linked to IBAN and card processing via partners that are incorporated and regulated in the EU. The highest risk is Transaction risk and includes but not limited to:
1. Transaction type.- Could the type of transaction be used for the purposes of money laundering or is it at a higher risk of money laundering? (Salary - low risk but Estate Agency - higher risk);-
Does the transaction make sense or is it overly complex given the underlying nature of the business being conducted?- Does it make sense that your client has asked your firm to carry out this type of transaction? (e.g. is it within your area of expertise/local geographical area?)
2. Value of transaction.
- Does the value of the transaction appear to fall within the financial means of the client, given their incoming savings?
3. Source of funds.- Is the source of funds clear and identifiable?- Are funds coming from a recored (regulated) financial/credit institution or are they personal funds?
• - Is any funding coming from overseas? Where from? Who from? Connection to the client?
• - Are any of the funds being paid by a third party otherwise unconnected to the
transaction?
4. Destination of funds.
• - Does transactional behavior match money flow declared by the client?
• - Any indications that account used as transit?
Customers. Risks from MPT PAY‘s own customer base, their type of business or the ultimate beneficiary of funds needs to be considered when MPT PAY enters and conducts business. MPT PAY is using third-party provider „Accuity“ to conduct PEP’s and Sanctions screening.
Customers are divided into two categories: Individuals and Entities. The risk level of Individual clients will be determined by the country of residence. The risk level of the Entity will be determined by their type of business.
Geography (Country) risk. Identifying geographic locations that may pose a higher risk is a core component of any inherent risk assessment and the business line will seek to understand and evaluate the specific risks associated with doing business in, opening and servicing accounts, offering products and services and/or facilitating transactions involving certain geographic locations.

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Reg. number: 11674181
Geography/Country risk may also be considered together with some of the other risk
factors in other risk categories, for example, in Clients for FIs, and in Products and Services for Transactions. For example, the percentage of a business division, unit or business line’s transactions with a high-risk country may provide an indication of the inherent risk from a Geography/Country perspective.
MPT PAY has created uses Country risk rating model.
Monitoring.
An element of a MPT PAY AML Policy in which client activity is reviewed for unusual or suspicious patterns, trends or outlying transactions that do not fit a normal pattern. Transactions are often monitored using software that weighs the activity against a threshold of what is deemed “normal and expected” for any given client. MPT PAY will rely on internal anti-money laundering system and controls. Monitoring is done automatically and manually by receiving alerts generated by the internal rules-based monitoring system.
Internal controls.
Policies, procedures, systems and personnel in within MPT PAY, designed to protect against the materialization of a ML risk, or to ensure that risk factors are promptly identified.
Unacceptable Levels of Risk.
MPT PAY will not knowingly conduct business with anyone who has engaged in any criminal activities. Further, MPT PAY will not enter into a business relationship with prohibited parties which include:
• Exact matches on Sanctions lists
• Foreign Shell Banks
• Unregistered Money Service Businesses (“MSBs”) • Parties that are not transparent
• Bearer shares
The MLRO will work with the senior management team and the Board to conduct a comprehensive review of all relevant customer information to determine the proper course of action.
AML Risk Limits
The MLRO has the responsibility to oversee all components of the AML Policy. It is the responsibility of the Board to ensure that there are appropriate and proportional systems and controls in place to mitigate the furtherance of financial crime.
The MLRO may recommend restrictions on business activities, existing or prospective, and such restrictions will be reported to the Board stating the reasons for such action. Business clients risk depends on the type of industry and risk of individuals based on country of residence.


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Jurisdiction risk
Jurisdictions we do not accept:
Reg. number: 11674181
Afghanistan
Eritrea
Equatorial Guinea
Palestine
American Samoa
Ethiopia
Pakistan
Aruba
Ghana
Russia
Antarctica
Guinea
Samoa
Azerbaijan
Guinea-Bissau
Sierra Leone
Bahamas
Guam
Somalia
Belarus
Guyana
South Sudan
Bosnia and Herzegovina
Haiti
Sudan
Botswana
Iran
Syria
Burundi
Iraq
Sri Lanka
Cambodia
Lebanon
Trinidad and Tobago
Central African Republic
Libya
Tunisia
Congo
Mali
Uganda
Congo, Democratic Republic
Montenegro
US Virgin Islands
Crimea and Sevastopol
Myanmar
Venezuela
Cuba
Nigeria
Yemen
Egypt
North Korea
Zimbabwe


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Jurisdictions we treat as a high risk:
Reg. number: 11674181
Anguilla Macau Isle of Man Armenia Maldives The Cayman Islands Barbados
Marshall Islands
Ukraine Belize Moldova United Arab Emirates Bolivia
Panama
USA Brazil Philippines Vanuatu British Virgin Islands Puerto Rico China Saint Vincent & Grenadines Costa Rica Saudi Arabia Curacao Serbia Dominica Seychelles Sources:
European Commission; European Parliament and the Council - list of high-risk third countries with strategic
deficiencies.

Consolidated List of European Union Financial Sanctions (EU sanction map).

TheFinancialActionTaskForce(FATF)-listofjurisdictionswithstrategicAML/CFTdeficiencies.

http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/fatf- compliance- june-2019.html (updated 21/06/2019)
https://www.knowyourcountry.com/country-ratings-table (updated 01/08/2019)