Money laundering is what criminals do to make dirty money look clean. It's a serious offence. And for a business like ours — one that processes card payments for contact centres and sits right in the flow of financial data — the risks are real and the stakes are high.
Clients hand us their payment infrastructure. If anyone ever tried to use our platform to launder money, it wouldn't just be a legal headache. It would break the trust our clients and their customers put in us every day. So we don't take chances.
We comply with every piece of anti-money laundering legislation that applies to us: the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. That's the legal floor. We go further than the floor. We won't knowingly provide services to anyone involved in money laundering, terrorist financing, or other financial crime. Full stop.
This policy applies to all Paytia operations worldwide, including our US entities and any customer we work with outside the UK. We run the same financial-crime controls wherever our platform is used.
Alongside the UK Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, we align with the US Bank Secrecy Act, FinCEN reporting obligations (including Suspicious Activity Reports and Currency Transaction Reports where applicable), and OFAC sanctions compliance. Where local law is stricter than these frameworks, we follow the stricter rule. Where it's weaker, we still hold the line described here.
All staff receive the same AML and sanctions training regardless of country, and our KYC, transaction monitoring, and reporting procedures apply globally. Local law adds to these commitments; it never reduces them.
This policy covers everyone at Paytia — employees, contractors, and any third party acting on our behalf, regardless of where they're based. Every part of our business needs to follow it. No exceptions.
We run periodic risk assessments to stay ahead of money laundering and terrorist financing threats. As a PCI DSS Level 1 certified platform processing card payments through contact centres, we pay particular attention to new products and services we launch, new technologies that create new payment channels, the nature and behaviour of our client relationships, and the geographies those clients and their customers operate in.
Before we take a client on, we need to know who they are and what they do. Our KYC process verifies identity so we're confident we know who we're dealing with, digs into the client's business and why they need our platform, works out the money laundering risk that particular client brings, and keeps watching transactions afterwards for anything that looks off.
Higher-risk clients, products, or countries get enhanced due diligence on top. That can mean more documentation, more frequent reviews, or senior sign-off before we move ahead.
Because we're in the business of processing payments, we're well placed to spot things that don't look right. We watch for transactions involving high-risk countries, unusually large or complex payments that don't fit a client's normal profile, patterns with no obvious commercial purpose (repeated small payments structured to stay under reporting thresholds is a classic one), and anything that could suggest terrorist financing.
If you spot something that doesn't look right, report it to our Money Laundering Reporting Officer (MLRO) immediately. Don't investigate it yourself and don't tip anyone off — that could itself be a criminal offence. The MLRO will assess the situation and decide whether to file a Suspicious Activity Report (SAR) with the National Crime Agency.
Good records do the heavy lifting here. We keep thorough documentation of everything tied to AML compliance: client identification and verification documents, transaction records, the risk assessments we've run, any suspicious activity reports filed, and staff training records.
We hold them for at least five years, or longer where the rules say so.
Everyone who needs to understand AML gets proper training. It's not a slide deck once a year. We walk people through their legal responsibilities (and these are personal, not just corporate), the regulatory framework we work inside, how our own policies and procedures play out day-to-day, and what suspicious activity actually looks like on the ground — along with how to report it.
Our compliance team reviews how well our AML controls are working on a regular rhythm. If something isn't up to scratch, we fix it quickly and flag it to senior management. Regulation keeps shifting, and we move with it. This policy gets rewritten when it needs to — it isn't a document that sits in a drawer.
Approved by the Paytia Board of Directors. Reviewed and updated annually.
If you have questions about our Anti-Money Laundering Policy or would like to report concerns, please contact compliance@paytia.com.