AML Policy

Doinpay (the “Company”)’s AML/CFT Policy is designed to ensure that the Company complies with the requirements and obligations set out in Cannada and international legislations, regulations, rules and Industry Guidance for the Money Service Operators (MSB) sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by the Company and employees and includes: • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the Company; • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking Relationships; • Establishing and maintaining risk-based systems and procedures to monitor ongoing customer activity; • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate; • Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities (e.g. JFIU) as appropriate; • The maintenance of appropriate records for the minimum prescribed periods; • The appointment of a Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO) of sufficient seniority, who have responsibility for oversight of the Company and Business Unit; • Training and awareness for all relevant employees; • Provision of appropriate management information and reporting to senior management of the Company; • The Company may require its clients to provide additional information or documentation to fulfil our legal obligations and where it deems appropriate refuse any client or transaction that is suspected of being related to financial crime.