AML Policy

Paysumo has a zero-tolerance approach to money laundering, terrorist financing and the facilitation of any financial crime. We maintain a risk-based anti-money laundering (AML) program that complies with the laws of the jurisdictions in which we operate.

All staff, management and third parties acting on our behalf are expected to comply with this policy and the procedures that support it.

We identify and verify every customer before establishing a business relationship. For corporate customers, we verify the entity, its directors, beneficial owners and authorized signatories. We also understand the nature and intended purpose of the business relationship.

Customers, transactions or jurisdictions presenting higher risk are subject to enhanced controls. EDD may include collecting source-of-funds and source-of-wealth information, additional identity verification, ongoing monitoring and senior management approval.

We monitor transactions using automated systems and manual review to detect unusual patterns, structuring, rapid movement of funds or other indicators of suspicious activity. Alerts are investigated, documented and escalated as appropriate.

We retain AML records, including customer identification documents and transaction records, for the minimum period required by applicable law. Records are stored securely and made available to regulators when required.

Where we suspect money laundering, terrorist financing or other criminal activity, we report it to the relevant regulator in the required form and timeframe. We do not tip off customers when a report is being prepared or has been filed.

Employees receive regular AML training tailored to their role. New joiners complete training before handling customer activity, and refresher training is delivered at least annually.

This policy is reviewed at least annually and whenever there is a material change in law, regulation, business model or risk exposure. Updates are communicated to staff and reflected in procedures.