StructaPay
1. Purpose
This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy outlines the principles and procedures implemented by StructaPay to prevent financial crime, money laundering, terrorist financing, fraud, and other illicit activities.
StructaPay applies a risk-based compliance framework aligned with international AML and CTF standards.
2. Scope
This policy applies to:
- All merchant applicants
- Beneficial owners and directors
- Authorized representatives
- Business partners and affiliates
All applicants must successfully complete identity and business verification prior to onboarding.
3. Customer Identification Procedures (KYC)
StructaPay conducts identity verification before establishing any processing relationship.
Required Information May Include:
- Legal company name
- Registration number
- Certificate of incorporation
- Memorandum & Articles of Association
- Director and shareholder information
- Ultimate Beneficial Owner (UBO) disclosure
- Government-issued identification
- Proof of address
- Corporate structure documentation
Enhanced documentation may be required depending on the risk profile of the business.
4. Risk-Based Assessment
Each merchant is evaluated under a structured risk assessment model that considers:
- Industry classification
- Geographic exposure
- Licensing status
- Business model transparency
- Traffic acquisition methods
- Historical processing performance
- Chargeback ratios
- Anticipated monthly volume
High-risk or regulated sectors may require Enhanced Due Diligence (EDD).
5. Enhanced Due Diligence (EDD)
EDD procedures may include:
- Source of funds verification
- Additional ownership documentation
- Regulatory licensing confirmation
- Compliance interviews
- Third-party verification checks
StructaPay reserves the right to decline applications that fail enhanced review standards.
6. Ongoing Monitoring
Merchant accounts are subject to continuous monitoring.
This may include:
- Transaction monitoring
- Volume pattern analysis
- Chargeback ratio monitoring
- Periodic documentation updates
- Compliance re-verification
Material changes in business activity must be disclosed immediately.
7. Sanctions & Screening
StructaPay conducts:
- Sanctions list screening
- Politically Exposed Persons (PEP) checks
- Adverse media screening
- Jurisdictional risk analysis
Businesses or individuals appearing on international sanctions lists will not be onboarded.
8. Suspicious Activity Reporting
If suspicious activity is detected, StructaPay may:
- Request clarification or additional documentation
- Suspend processing activity
- Terminate services
- Report activity to relevant financial or regulatory authorities where required
9. Record Keeping
All documentation collected during onboarding and monitoring is retained in accordance with applicable regulatory requirements and internal compliance procedures.
10. Merchant Obligations
Merchants agree to:
- Provide accurate and complete information
- Update StructaPay regarding material changes
- Maintain lawful operations
- Cooperate with compliance requests
Failure to comply may result in immediate suspension or termination.
11. Policy Updates
StructaPay reserves the right to update this KYC / AML Policy to reflect regulatory changes or operational adjustments.