| Money Laundering Policy |
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The prevention of money laundering is a key focus of regulatory authorities in developed countries. The prevention of money laundering inhibits the movement of funds derived from criminal activity and restricts the availability of money to fund terrorist activities. PaySum1 is committed to preventing money laundering through its service and complies with regulatory requirements. Depending on the origins of a Clients payment, PaySum1 may report suspicious activity to regulatory authorities in one or more countries. PaySum1 may conduct additional security checks on Clients, CSP’s and Merchants at our discretion. Clients should assume all information provided to PaySum1 is available to regulatory authorities in both the country of origin of the funds, and the destination country of the funds. PaySum1 does not accept payment by credit card or debit card. PaySum1 will only pay into a bank account at the receiving end of one of our licensed Commerce Service Providers (CSP’s) who in turn will only make payment to one of their Merchants with whom they have signed a legal contract detailing the terms and conditions of the service. PaySum1 will not accept or pay out cash. In the event that the Client deposits cash into the PaySum1 account, as it is not possible to stop this occurrence, PaySum1 will assess each of these deposits independently. PaySum1 reserves the right to refuse to process a transaction at any stage, where it believes the transaction to be connected in any way to money laundering or criminal activity. PaySum1 is prohibited from informing a Client that they have been reported for suspicious activity. PaySum1 is obliged to, and will automatically report suspicious transactions or behaviour to the relevant authorities. 1. Breaking a large transaction into smaller transactions to avoid reporting PaySum1 applies a risk based approach when identifying Clients and understanding the Client’s transactions. The principal of substance over form may be applied at times in order to get a better understanding of the Client, their practices and their intentions. In all cases the licensed CSP will require a proof of address from each contracted Merchant. PaySum1 will only pay funds to bank accounts held in the name of licensed CSP’s. The CSP will perform a KYC check before signing up a Merchant. Merchants will only make payment to recognized bank accounts in the name of the Merchant with whom KYC has been performed and a contract signed. By restricting the source and the destination of funds to those which are already in the banking system, we are increasing the probability that the funds are moving from and to a reputable source. |

