As a financial institution, SWIPELOCAL is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering procedures. SWIPELOCAL policy is to prevent and detect money laundering, fraud, and other illegal activities.
This policy is drafted on the basis of nature of our business, type of client and transaction, etc. to satisfy itself that the measures taken by it are adequate and appropriate
Definition Below:
Money Laundering is the process by which illegal funds are converted into legitimate funds.
It is the attempt to conceal or disguise the nature, location, source, ownership or control of illegally obtained money. However other individuals may attempt to launder money in order to conceal their identity or finance their operations
Additionally, the adverse effects, including the adverse publicity to the Firm associated with involvement in money laundering events cannot be emphasized enough. Money laundering transitions may include:
- Money laundering can involve the proceeds of Corruption and Bribery, Misuse of Non-Profit Organizations, drug dealings, arms dealings, mail fraud, bank fraud, wire fraud or securities fraud, among other activities.
- ‘Suspicious activity’ is a very difficult concept to define because it can vary from one transaction to another based upon all the circumstances surrounding the transaction or group of transactions. For example, transactions by one customer may be normal based on our knowledge of that customer and their pattern of activity, while similar transactions by another customer may be suspicious. Many factors are involved in determining whether transactions are suspicious including the amount, the ship to address and frequency of orders.
▪ Application Form
▪ Valid Passport/Emirates ID of Beneficial Owner(s) & Signatory
▪ Personal Utility Bill (No older than 3 months) of Beneficial Owner(s)
▪ Personal & Company Bank Statements (No older than 3 months)
▪ Incorporation/Registration Certificate
▪ Memorandum of Association
▪ Register of Shareholder(s) & Director(s)
▪ For businesses with monthly processing volume in excess of USD 100k, all KYC documents must be notarized.
▪ Regulatory License, if applicable.
▪ Settlement proceeds are only wired to business bank account, no personal account
▪ While auditing, if Merchant account falls within a high-risk compliance category then the same will be Disapproved/Rejected.
▪ Customer Profile Identification
▪ Ongoing monitoring of account activity
▪ Reporting of suspicious activity
Suspicious transaction monitoring & reporting. We ensure that appropriate steps are taken to recognized suspicious transactions and have appropriate procedures for reporting suspicious transactions.
▪ Customers transacting for large sums of money (in USD) from overseas locations
▪ Monitoring (If any transaction patterns found to be suspicious then the same is being highlighted to Merchants). The notification is being sent via email with specific nature/reason of suspicion
▪ Customer KYC documents are obtained like photo ID proof and bank statement copy or card copy (which reflects only the beginning 6 & ending 4 digits) for verification
▪ In case of Confirmed Fraud transactions, Merchant is advised to Cancel the transaction & proceed with Refund
▪ Identifying trends in fraud
▪ Empirical trend analysis (observation)
▪ Historical trend analysis (past experiences)
a) Prohibited Items -The Customer assures, undertakes and guarantees that the following products and services shall not be sold on the Customer’s Website and / or no transactions shall be processed through the Payment Gateway Facilities herein by SWIPELOCAL for following Products and Services:
(i) Adult goods and services which includes pornography and other sexually suggestive materials (including literature, imagery and other media); escort or prostitution services;
(ii) Alcohol which includes Alcohol or alcoholic beverages such as beer, liquor, wine, or champagne;
(iii) Body parts which include organs or other body parts;
(iv) Bulk marketing tools which includes email lists, software, or other products enabling unsolicited email messages (Spam);
(v) Cable descramblers and black boxes which includes devices intended to obtain cable and satellite signals for free;
(vi) Child pornography which includes pornographic materials involving minors;
(vii) Copyright unlocking devices which includes Mod chips or other devices designed to circumvent
Copyright Protection;
(i) Copyrighted media, which includes unauthorized copies of books, music, movies, and other licensed or protected materials;
(ii) Copyrighted software, which includes unauthorized copies of software, video games and
licensed or protected materials, including OEM or bundled software;(iii) Counterfeit and unauthorized goods which includes replicas or imitations of designer goods; items without a celebrity endorsement that would normally require such an association; fake autographs, counterfeit stamps, and other potentially unauthorized goods;
(iv) Drugs and drug paraphernalia which includes illegal drugs and drug accessories, including herbal drugs like salvia and magic mushrooms;
(v) Drug test circumvention aids which includes drug cleansing shakes, urine test additives, and related items;
(vi) Endangered species, which includes plants, animals or other organisms (including product derivatives) in danger of extinction;
(vii) Gaming/gambling which includes lottery tickets, sports bets, memberships/ enrolment in online gambling sites, and related content;
(viii) Government IDs or documents which includes fake IDs, passports, diplomas, and noble titles
(ix) Hacking and cracking materials which includes manuals, how-to guides, information, or equipment enabling illegal access to software, servers, websites, or other protected property
(x) Illegal goods, which includes materials, products, or information promoting illegal goods or enabling illegal acts;
(xi) Miracle cures which includes unsubstantiated cures, remedies or other items marketed as quick health fixes;
(xii) Offensive goods, which includes literature, products or other materials that: a) Defame or slander any person or groups of people based on race, ethnicity, national origin, religion, sex, or other factors b) Encourage or incite violent acts c) Promote intolerance or hatred;
(xiii) Offensive goods, crime that includes crime scene photos or items, such as personal belongings, associated with criminals;
(xiv) Prescription drugs or herbal drugs or any kind of online pharmacies which includes drugs or other products requiring a prescription by a licensed medical practitioner;
(xv) Pyrotechnic devices and hazardous materials which includes fireworks and related goods; toxic, flammable, and radioactive materials and substances;
(xvi) Regulated goods which includes air bags; batteries containing mercury; Freon or similar substances/refrigerants; chemical/industrial solvents; government uniforms; car titles; license plates; police badges and law enforcement equipment; lock-picking devices; pesticides; postage meters; recalled items; slot machines; surveillance equipment; goods regulated by government or other agency specifications;
(xvii) Securities, which includes stocks, bonds, or related financial products;
(xviii) Tobacco and cigarettes which includes cigarettes, cigars, chewing tobacco, and related products;
(xix) Traffic devices, which includes radar detectors/hammers, license plate covers, traffic signal changers, and related products;
(xx) Weapons which includes firearms, ammunition, knives, brass knuckles, gun parts, and other armaments;
(xxi) Wholesale currency, which includes discounted currencies or currency, exchanges;
(xxii) Live animals;
(xxiii) Multi-Level marketing collection fees;
(xxiv) Matrix sites or sites using a matrix scheme approach;
(xxv) Work-at-home information;
(xxvi) Any product or service, which is not in compliance with all applicable laws and regulations whether federal, state, local or international including the all laws of UAE.
Procedures are intended to ensure that, prior to remitting funds to Merchants, all measures are taken to confirm the merchant identities and transactions are not illegitimate. Merchant Identification Procedures are based on the premise that the SWIPELOCAL will accept funds from a new and existing merchant only after:
✓ Merchant identity (KYC) is collected during onboarding (documentation to help prove identity)
✓ Based on Merchant Business required License for running the Business or proper documents are collected (for business verification purposes)
✓ Obtain details on Ticket Size/volume of transactions
✓ Checks if Merchant (Promoters/ owner/ website/ legal entity) is the subject of reviews indicating possible criminal, civil or regulatory violations
✓ We evaluate & ensure that Merchant is in good/legitimate business practice
✓ If the Merchant is found violating TNC agreed upon registration or is involved in wrongful business in that case same will be highlighted & asked to provide clarification & supporting’s. Post which same will be reviewed & processed for deactivation
• Merchant attempts to make transactions from his own credit cards in return to cash payments from customer.
• Merchant engages in unusual or frequent payments from particularly to unfamiliar payment options. i.e. (Sudden increase in transactions of an individual with no justification)
• Providing misleading information in-order to accept funds/transactions
Responsible officer will maintain a record of list of the types of merchants that SWIPELOCAL considers to be of ‘Risky’ or ‘Fraud’ such that enhanced due diligence procedures are warranted compared to the routine Merchant Identification Procedures. Following are the examples of Merchants who pose high transaction laundering which is the digital evolution of money laundering.
- Creating Bogus Companies
- Stock Market
- Nonprofit organizations – charities High risk services
- Casinos & gambling
- Money Changers/Currency exchange websites
- Property Market
- Operational Risk (Failed internal processes, systems & technology)
As part of the SWIPELOCAL anti money laundering program, Employees are expected to be fully aware of the anti-money laundering policies and understand their responsibilities. To ensure the continued adherence to antimoney laundering policies and procedures, which are as mentioned.
• To undertake training programs on anti-money laundering policies and procedures
• To comply with the requirements of Rules & Regulations
• To ensure that reports are properly filed as required
- Safe guarding or Protecting Merchant/Customer data
- Shredding forms or notes which is important after the required attention
The risk to SWIPELOCAL of contravening the anti-money laundering legislation will be assessed on a periodic basis and the adequacy and effectiveness of the Anti-Money Laundering Policy will be reviewed in light of such assessments.
The policy shall be reviewed from time to time as and when required by the Management but at least once in a year, to ensure that it remains compliant with good practice Central bank of U.A.E. & Banking standards.