Anti-Money Laundering

Introduction

At SoonaPay, we are committed to the highest standards of integrity and transparency across all our financial operations. Anti-Money Laundering (AML) compliance is fundamental to ensuring adherence to applicable international laws and regulations. This policy aims to protect our customers and our financial system from any unlawful use or suspicious activity. We are also committed to complying with Counter-Terrorism Financing (CTF) regulations in accordance with local and international laws.

Definition of Money Laundering and Terrorism Financing

Money Laundering

Money laundering is the process of concealing the illicit origin of funds derived from illegal activities, such as financial crimes or tax evasion, by converting them into apparently legitimate sources. This process takes place through three main stages:

• Placement: Introducing illicit funds into the financial system.
• Layering: Conducting multiple financial transfers to obscure the original source.
• Integration: Reintroducing the funds into the economy through legitimate investments.

Terrorism Financing

Terrorism financing is the provision or collection of funds to support terrorist activities, whether those funds are obtained legally or illegally. Such operations may involve the transfer of small amounts that are difficult to trace.

Our Commitment to AML/CTF

SoonaPay is committed to following the procedures below to ensure full compliance with anti-money laundering and counter-terrorism financing regulations:

• Complying with the laws of the United Kingdom, the European Union, and the United Nations, in addition to other relevant international regulations.
• Implementing Know Your Customer (KYC) policies to verify and document customer identities.
• Monitoring transactions to detect any suspicious activities.
• Reporting any suspicious transactions to the competent authorities.
• Training employees on AML/CTF procedures on an ongoing basis.

Compliance Policies and Procedures

Know Your Customer (KYC)

The identity of all customers is verified before they are granted access to our services, through:

• Requesting official identification documents such as a passport, national ID, or driving licence.
• Verifying the source of funds to ensure their legitimacy where necessary.
• Screening against international sanctions lists and any applicable embargo lists.
• Verifying residential address using utility bills or bank statements.

Monitoring Suspicious Transactions

We monitor all transactions carried out through our platform using advanced analytics systems to detect any abnormal behaviour, including:

• Repeated high-value transactions without a clear justification.
• Transactions between parties with no apparent financial or commercial relationship.
• The use of multiple payment methods in an unusual manner.
• Transferring funds to high-risk regions or countries subject to financial sanctions.

Reporting Suspicious Activity

If any unlawful activity is detected, we are committed to reporting it in accordance with applicable laws by submitting reports to the competent authorities, such as:

• The Financial Intelligence Unit (FIU) in the United Kingdom.
• Any other relevant local or international regulatory bodies.
• Refraining from notifying the customer of the report (tipping off prohibition) in accordance with the law.

Record Keeping

We are committed to retaining records relating to all customers and transactions for a minimum of 5 years after the end of the business relationship, including:

• Identity verification documents.
• Financial transaction data.
• Any reports submitted regarding suspicious activities.

How We Protect Our Users

• Implementing robust verification systems for identities and documents.
• Imposing limits on transfer volumes to reduce risk.
• Conducting periodic reviews of customer accounts and suspicious transactions.
• Adopting advanced encryption technologies to protect customer data.
• Cooperating with banks and financial institutions to verify sources of funds.

Customer Responsibilities

• Providing accurate and complete information when registering.
• Not using SoonaPay services for any unlawful purposes.
• Immediately reporting any suspicious activity on the account.

Reporting Suspicious Activity

If you suspect any unlawful transaction, you can contact our compliance team by email at compliance@soona-pay.com or via the contact form available on our website. All reports are handled with complete confidentiality.

Penalties and Disciplinary Measures

SoonaPay reserves the right to take the following measures against any customer or employee proven to be involved in money laundering or terrorism financing activities:

• Immediately suspending or closing the account.
• Notifying the competent authorities.
• Taking legal action where necessary.

Frequently Asked Questions