KYC & AML Policy

BinaxPay Business — KYC & AML Policy

Last Updated: 16 January 2026

1. 1. Introduction

   This KYC & AML Policy outlines how BinaxPay ("we," "us," or "our") complies with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) obligations. It applies to all business clients, directors, beneficial owners, and authorised representatives using our Business Platform (binaxpay.com/business).

2. 2. Legal Framework

   BinaxPay follows the UK Money Laundering Regulations 2017 (as amended), EU 5th & 6th AML Directives, FCA guidance, and FATF Recommendations. These require identification, verification, monitoring, and reporting to prevent illicit finance.

3. 3. Objectives

   • Prevent money laundering, terrorism financing, and related financial crime.
   • Meet national and international AML/CTF/KYC obligations.
   • Protect the integrity and reputation of BinaxPay and its financial partners.
   • Support transparency and traceability of transactions.

4. 4. Customer Identification (KYC)

   Before activating services, all clients must complete KYC. We collect and verify:

   • Business Details: Legal name, registration number, tax ID, incorporation certificate, registered address, ownership structure.
   • Directors & UBOs: Full name, date of birth, nationality, and government-issued ID.
   • Authorised Representatives: Proof of identity and authority (e.g., PoA/board resolution).
   • Additional Documentation: Proof of address and supporting business activity evidence where required by risk.

5. 5. Verification Methods

   We use internal checks and regulated providers to verify identity, including:

   • Electronic identity verification (eIDV) via approved databases and registries.
   • Document and biometric verification.
   • Sanctions, watchlist, and PEP screening (e.g., UK OFSI/HMT, EU, UN, OFAC).
   • Enhanced Due Diligence (EDD) for high-risk clients, sectors, or jurisdictions.

6. 6. Ongoing Monitoring

   Accounts and transactions are monitored to detect unusual or high-risk activity, including:

   • Transaction profiling, volumes, counterparties, and frequency.
   • Jurisdictional and sector risk assessments.
   • Pattern and anomaly detection with real-time alerts.
   • Periodic KYC refresh and re-verification based on risk.

7. 7. Suspicious Activity Reporting (SAR)

   Suspected money laundering, terrorist financing, or sanctions evasion is escalated to Compliance. We file Suspicious Activity Reports with the relevant authority (e.g., UK National Crime Agency) where required.

8. 8. Risk Assessment

   Each customer is risk-rated using factors such as business model, geography, transaction patterns, delivery channels, and ownership. High-risk cases are subject to EDD and senior management approval.

9. 9. Record Keeping

   KYC files, verification data, SAR records, and transaction information are stored securely for at least 10 years after account closure or longer if required by law. Access is restricted and logged.

10. 10. Sanctions & Restricted Entities

    We do not onboard or service individuals or entities subject to applicable sanctions or engaged in prohibited activities (including unlicensed gambling, illegal trade, or terrorism). High-risk third countries identified by UK/EU frameworks may be restricted.

11. 11. Employee Training & Oversight

    All relevant employees receive initial and periodic AML/KYC/CTF training. The Compliance Officer oversees monitoring, investigations, SAR filings, audits, and policy adherence.

12. 12. Data Protection

    Personal and corporate data collected for AML/KYC is processed in line with our Privacy Policy, UK GDPR, EU GDPR, and the UK Data Protection Act 2018.

13. 13. Cooperation with Authorities

    We cooperate with law enforcement, regulators, and Financial Intelligence Units (FIUs) as required by law. Disclosures are made only where legally obligated.

14. 14. Updates to This Policy

    We may update this policy to reflect regulatory changes and internal risk controls. The latest version and effective date will be published on our website.

15. 15. Contact Information

    For questions, compliance concerns, or to report suspicious activity, contact:

    BinaxPay Holding Ltd
    Company No. 16830503.
    167–169 Great Portland Street, 5th Floor, London, England, W1W 5PF
    Phone: +49 163 333 25 43
    Email: [email protected]
    Compliance & CEO Contact: [email protected]