GLOBEXPAY LTD is committed to upholding the highest standards of anti-money laundering (AML) practices. The GLOBEXPAY LTD AML Policy is designed to prevent the misuse of its services in connection with money laundering, terrorist financing, fraud, and other financial crimes. To achieve this, GLOBEXPAY LTD has implemented an Anti-Money Laundering Program (“AML Program”), outlined below, and may request the following information from its customers:
a) GLOBEXPAY LTD reserves the right to request proper documentation to verify your identity and/or your business. Additional personal or business information, as well as bank account details, may also be required.
b) GLOBEXPAY LTD reserves the right to conduct specific identification checks as part of the screening process for accounts under scrutiny or listed on international watchlists.
c) GLOBEXPAY LTD may request the aforementioned information during the account application process to provide services.
d) GLOBEXPAY LTD reserves the right to regularly review the provided information as part of ongoing account monitoring, in line with its AML policy and applicable laws and regulations.
The AML Program is designed to mitigate money laundering risks identified by GLOBEXPAY LTD. This is achieved through Board-approved policies, principles, and standards, along with effective controls to protect GLOBEXPAY LTD, its employees, shareholders, and customers from money laundering activities. The AML Program guides all employees to ensure compliance with relevant AML laws, rules, and regulations.
Based on the laws of England and Wales, as well as the regulatory requirements in all jurisdictions where GLOBEXPAY LTD operates, the AML Program includes:
• The appointment of a Money Laundering Reporting Officer (“MLRO”), as mandated by local regulations
• A Customer Due Diligence (“CDD”) Program, incorporating Customer Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) protocols, along with the remediation of CDD for existing customers
• Enhanced Due Diligence (“EDD”) for higher-risk customers, such as Politically Exposed Persons (“PEPs”), their relatives, and close associates
• Systems and processes to monitor customer transactions for suspicious activity
• Investigation and reporting of suspicious activities to the appropriate regulatory bodies
• Regular independent audits and ongoing AML training for all employees
• Compliance with any additional local requirements.