Anti-Money Laundering (AML) Policy

This policy applies to all PayEurasia employees, contractors, merchants and providers that transact through our payment infrastructure across Bangladesh, India, Pakistan, Nepal and any additional corridor we support.

We assess every merchant relationship for money-laundering, terrorist-financing, sanctions, fraud and reputational risk before onboarding, and continuously thereafter. Risk ratings drive the frequency and depth of ongoing monitoring, enhanced due diligence and periodic review.

• Identification and verification of the merchant legal entity, directors and ultimate beneficial owners (UBOs at 25% or per local threshold).
• Understanding of business model, product, expected volumes, geographies and end-customer base.
• Enhanced Due Diligence (EDD) for higher-risk categories, PEP exposure, or high-risk jurisdictions.
• Refresh of KYC/KYB records on a periodic basis and on trigger events.

Merchants, UBOs and payout beneficiaries are screened against consolidated sanctions lists (UN, OFAC, EU, UK HMT and relevant local lists) and PEP databases at onboarding and on an ongoing basis. Positive matches are escalated and blocked pending review.

All payment flows are subject to automated monitoring rules covering velocity, structuring, unusual counterparty patterns, high-risk geographies and deviations from the merchant's expected profile. Alerts are reviewed by trained analysts and escalated where appropriate.

Where our compliance team forms a suspicion of money laundering, terrorist financing or predicate offences, we file Suspicious Transaction Reports (STRs / SARs) with the competent Financial Intelligence Unit and cooperate with lawful requests from regulators and law enforcement. Tipping-off is strictly prohibited.

KYC records, transaction data and STR files are retained for the periods mandated by local law (typically five years from account closure or transaction date, whichever is later).

PayEurasia designates a Money Laundering Reporting Officer (MLRO). All relevant staff complete AML/CTF training at onboarding and annually thereafter. The program is reviewed at least annually and updated to reflect regulatory change.

PayEurasia will not knowingly process payments related to sanctioned parties, unlicensed financial services, terrorist financing, human trafficking, child exploitation material, or any activity prohibited by our Acceptable Use Policy.

Compliance and law-enforcement enquiries: compliance@payeurasia.com.