AML/KYC Public Policy

AML/KYC Public Policy — WayToPay

WayToPay

Last updated: 05 August 2025

Contact: [email protected]

1. General Provisions

This policy is developed in accordance with:

• Regulation on Markets in Crypto-Assets (MiCA);
• EU Anti-Money Laundering Directive 5 (AMLD5);
• Regulation (EU) 2016/679 (GDPR);
• FATF Recommendations;
• National legislation of the country of registration.

Objective: To prevent the use of the WayToPay platform for money laundering, terrorist financing, fraud, and other illicit activities.

2. Scope

This Policy applies to:

• All users (individuals and legal entities) of the WayToPay platform;
• All employees, contractors, and partners involved in client servicing, monitoring, or compliance.

3. Risk-Based Approach

WayToPay implements a risk-based approach (RBA):

• Each client is assigned an individual risk level (low, medium, high);
• CDD (Customer Due Diligence) or EDD (Enhanced Due Diligence) is applied based on risk level;
• WayToPay may refuse service in case of high-risk assessment.

4. Customer Identification and Verification (KYC)

For Individuals:

• Full name, date of birth, nationality;
• Passport or national ID;
• Screening for sanctions, PEP status, and adverse media;
• Selfie and liveness check.

For Legal Entities:

• Registration documents and structure;
• Beneficiaries and directors;
• Verification of representative's authority;
• Screening for sanctions and PEPs.

Verification is conducted via certified providers (e.g., SumSub, Veriff, etc.).

5. Transaction Monitoring

WayToPay continuously monitors all transactions using:

• Automated monitoring and filtering systems;
• Limits, flags, and triggers;
• Requests for supporting documents;
• Possible freezing of funds and/or account suspension.

6. Suspicious Activity

In case of reasonable suspicion of illicit activity:

• WayToPay suspends service provision;
• All actions are recorded;
• Data is reported to the FIU or relevant regulatory authorities;
• Clients are not notified (tipping-off is strictly prohibited).

7. Service Refusal

WayToPay reserves the right to:

• Refuse to establish business relationships;
• Terminate existing services;
• Withhold explanation if required by applicable law.

8. Data Retention

All KYC/AML-related data is retained for at least 5 years after termination of the business relationship;

Stored securely in compliance with GDPR and MiCA.

9. Confidentiality

Access to data is restricted to authorized personnel only;

Data protection complies with GDPR and the company's Privacy Policy.

10. Review and Updates

This policy is reviewed and updated at least once a year;

Updates are made in case of legal or operational changes;

The current version is publicly available on the WayToPay website.

For AML/KYC inquiries:

[email protected]