PAYEX AML/KYC/CFT POLICY
As an obliged person under Estonia Money Laundering and Terrorist Financing Prevention Act, PayEx
OÜ (Payex) have an obligation to assist in the efforts to prevent the use of the financial system and
economic space of the Republic of Estonia for money laundering and terrorist financing.
In order to achieve this goal, firms must have in place detailed and robust policies and procedures for
prevention of money-laundering and terrorist financing (AML/CFT) to identify and mitigate the risks
associated with the firm’s product or service in terms of money laundering and terrorist financing.
Money Laundering is defined as:
1) The conversion or transfer of property derived from criminal activity or property obtained instead of
such property, knowing that such property is derived from criminal activity or from an act of participation in
such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any
person who is involved in the commission of such an activity to evade the legal consequences of that
person’s actions;
2) the acquisition, possession or use of property derived from criminal activity or property obtained
instead of such property, knowing, at the time of receipt, that such property was derived from criminal
activity or from an act of participation therein; and
3) the concealment or disguise of the true nature, source, location, disposition, movement, rights with
respect to, or ownership of, property derived from criminal activity or property obtained instead of such
property, knowing that such property is derived from criminal activity or from an act of participation in such
an activity.
Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and
counselling the commission of any of the activities referred to above is also considered money
laundering.
Terrorist Financing is defined as:
The financing and supporting of an act of terrorism and commissioning thereof within the meaning of the
Penal Code of Estonia.
All firms must adhere to the Money Laundering and Terrorist Financing Prevention Act of Estonia, and be
aware of the guidance set down by the AML/CFT Committee, Financial Supervision Authority and
Financial Intelligence Unit, and the recommendations from the Financial Action Task Force (FATF), an
inter-governmental body whose purpose is the development and promotion of national and international
policies to combat money laundering and terrorist financing.
This Policy covers the following areas:
▪ Internal Controls;
▪ Compliance Officer;
▪ Training;
▪ Customer Verification Procedures;
▪ Monitoring of Transactions; and
▪ AML Program Audit.
Internal Controls
We have designed a structured system of internal controls in order to comply with applicable AML/CFT
laws and regulations, some of which are outlined in this Policy including, but not limited to:
▪ establishing customer's identity and verifying the information provided;