Anti money laundering policy
Paydex’s framework for preventing money laundering, terrorist financing and sanctions evasion across merchant onboarding, monitoring and reporting.
Last updated: 1 September 2025
1. Purpose
Paydex is committed to preventing the use of its services for money laundering, terrorist financing, sanctions evasion and other financial crime. This policy summarises the framework we apply to merchants, partners and transactions.
2. Regulatory framework
Our programme follows the FATF Recommendations, the Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance, applicable EU and UK regulations for the markets we serve, and the rules of Visa and Mastercard.
3. Know Your Business (KYB)
- Verification of legal entity, registration and ownership structure.
- Identification of directors and ultimate beneficial owners holding 25% or more.
- Screening against sanctions, PEP and adverse-media lists.
- Review of the business model, website and expected transaction profile.
4. Risk-based approach
Each merchant is assigned a risk rating (low, medium, high) that determines the depth of due diligence, monitoring thresholds and review frequency. Enhanced due diligence is applied to high-risk industries, jurisdictions and ownership structures.
5. Transaction monitoring
Automated rules and adaptive models monitor transactions in real time for unusual patterns: velocity spikes, structuring, mismatch between declared and actual activity, and links to sanctioned parties. Alerts are reviewed by the compliance team within one business day.
6. Reporting
Suspicious activity is reported to the relevant financial intelligence unit in accordance with the law. Paydex does not inform the merchant when such a report is filed (“no tipping off”).
7. Record keeping
KYB documents, transaction records and investigation files are retained for at least five years after the end of the business relationship.
8. Training and governance
All employees receive AML training at onboarding and annually thereafter. The Money Laundering Reporting Officer reports to the Board and the programme is independently audited every year.
9. Contact
Questions about this policy: compliance@paydex.co.uk.