Anti-Money Laundering Policy (AML)The money laundering is the criminal process of converting the amounts of illegally obtained money (by terrorism, corruption, drug dealing, etc.) with hiding its true source into legal investments. It happens because illegal nature of such funds will not be discovered due to them becoming of material values.
The government of every country fights against money laundering and terroristic financial operations because it is necessary to prevent the entry of criminal funds into the economy. Financial and commercial institutions are the most easily accessible for illegal processes of terroristic and criminal organizations. Especially digital currency services are vulnerable. Thus, Zion company takes an active part in the prevention of such criminal activity in the whole world.
For these goals we do the following actions:
1. We conduct the process of verification of the client’s identity and personal information and monitor all transactions made by customers.
2. Our team traces all suspicious operations of users and also those made under irregular circumstances.
3. If our company suspects the illegal activity or money laundering, it has the full right to request additional verification or cancel such transaction at any step.
4. According to the international law, Zion is not obligated to give customer any notifications about suspicion in the user’s criminal actions.
5. Such company’s actions are based on the AML FATF references.
To prevent the suspicious operations and verify the client’s identity, the team of our company has the right to update its electronic system on the regular basis according to new regulations (if those appear). We also arrange various trainings for our staff for improving the methods of struggle against money laundering.
At the Company level: threats and vulnerabilities that put the Company at risk of being used to facilitate ML/TF
All clients default to low risk, UNLESS risk factors are present such as; Automatic high-risk characteristics – if any of the flags below are present the client is high risk.
- Politically exposed person
- A client where a suspicious transaction, terrorist financing report has been filed
- A client who is an identified terrorist
- A client for whom we are unable to obtain beneficial ownership information
- A client from high-risk country
Client characteristics, product, service, delivery channel:
- Politically exposed person, head of international organization and close associates;
- Unknown source of funds;
- Large transaction (ETF) orders from/to high-risk foreign jurisdictions;
- Third party involvement without reasonable justification;
- Occupation – High-risk occupations (e.g., cash intensive businesses, offshore business, business in high-risk countries, online gambling);
- Client’s business structure or transactions seems unusually complex;
- Non face-to-face client identification without justifiable reason.
Geography:
- Client resides outside local or normal client area;
- Client resides in known crime area;
- Client has offshore business activities, client connections to high-risk countries.
Other suspicious transaction indicators:
- Volume/timing/complexity of transactions inconsistent with the client’s personal/business activity and/or purpose of the services/account;
- Value of deposits/transfers inconsistent with occupation or source of funds;
- Presence of any suspicious transaction indicators outlined in Part A “Background information” section
Indicators of suspicious transactions or potential high-risk clients
The following are some samples of some general and industry-specific indicators that might lead you to have reasonable grounds to suspect that a transaction is related to a money laundering or terrorist activity financing offence. The presence of one or more of these factors that a deeper look should be taken.
General indicators. The following are a few examples of general indicators that might lead us to suspect that a transaction is related to a money laundering or terrorist activity financing offence. It will not be just one of these factors alone, but a combination of several factors in conjunction with what is normal and reasonable in the circumstances of the transaction or attempted transaction.
- Client admits to or makes statements about involvement in criminal activities;
- Client refuses or tries to avoid providing information required, or provides information that is misleading, vague, or difficult to verify;
- Client produces seemingly false documentation that appears to be counterfeited, altered or inaccurate;
- Client appears to have accounts with several financial institutions in one area for no apparent reason;
- Client repeatedly uses an address but frequently changes the name involved;
- Client shows uncommon curiosity about internal controls and systems;
- Client presents confusing details about the transaction;
- Client makes inquiries that would indicate a desire to avoid reporting;
- Client is involved in unusual activity for that individual or business;
- Client presents confusing details about the transaction or knows few details about its purpose;
- Client seems very familiar with money laundering or terrorist activity financing issues;
- Client refuses to produce personal identification documents;
- Client frequently travels to a high-risk country.
Industry specific examples- Client requests a transaction at a foreign exchange rate that exceeds the posted rate.
- Client wants to pay transaction fees that exceed the posted fees.
- Client exchanges currency and requests the largest possible denomination bills in a foreign currency.
- Client knows little about address and contact details for payee, is reluctant to disclose this information, or requests a bearer instrument.
- Client wants a cheque issued in the same currency to replace the one being cashed.
- Client wants cash converted to a cheque and you are not normally involved in issuing cheques.
- Client wants to exchange cash for numerous postal money orders in small amounts for numerous other parties.
- Client enters into transactions with counter parties in locations that are unusual for the client
- Client instructs that funds are to be picked up by a third party on behalf of the payee.
- Client makes large purchases of traveler’s cheques not consistent with known travel plans.
- Client makes purchases of money orders in large volumes
Restricted Activities and Clients
To mitigate and control ML risk related to client, Website does not provide services and refuse account opening for the following clients with unacceptable risk level:
- Private individuals with the following personal and/or business activity information of the negative nature is available about the client, which indicates their possible relation to the proceeds of crime or laundering or terrorism if the information is received from trusted sources, such as World Check and public authorities websites;
- client funds have previously been frozen or arrested in connection with suspected criminal activity;
- reinsurance services, when the service provider is not properly licensed and there is a lack of supervision of the service provider;
- the client is trying to avoid the provision of information or is trying to hide their economic activity;
- trafficking in arms and ammunition;
- economic activity, that has to be registered in the legal entity form;
- unlicensed foreign currency exchange intermediary services (such as forex dealers, Binary options), as well as other unlicensed investment services; h. client's transactions or payments are complex, unusually large for the customer's economic or personal activity or are unclear in terms of their legal and economic objective;
- Escort services organisation / activities and / or distribution of erotic / pornographic videos and pictures and other related services;
- Cash collection services;
- Debt recovery services provider;
- Drugs, vitamins and nutritional supplements distribution; m. Detective services provider;
- Direct marketing services provider;
- Pyramid schemes;
- Telemarketing;
- Pawnshop services provider;
- Auctions and related services provider;
- Tobacco and alcohol products distribution.
Legal persons with the following personal and/or business activity:
- the client is trying to avoid the provision of information or is trying to hide their economic activity;
- information of the negative nature is available about the client, which indicates their possible relation to the proceeds of crime or laundering or terrorism if the information is received from trusted sources, such as World Check and public authorities websites;
- client funds have previously been frozen or arrested in connection with suspected criminal activity;
- reinsurance services, when the service provider is not properly licensed and there is a lack of supervision of the service provider;
- trafficking in arms and ammunition;
- investment services and investment ancillary services, when the service provider is not properly licensed in the European Economic Area or in another country, where the legislative requirements of anti-money laundering and terrorism financing are equivalent to the European Union legislation;
- legal entities, which are recognized as shell companies;
- unlicensed gambling services organization;
- the reason for the client's legal entity's establishment is unclear and the client 6 of the legal and the information about the client's economic objectives are vague and ambiguous;
- unlicensed foreign currency exchange intermediary services (such as forex dealers, Binary options);
- client's transactions or payments are complex, unusually large for the customer's economic or personal activity or are unclear in terms of their legal and economic objective;
- Escort services organisation / activities and / or distribution of erotic / pornographic videos and pictures and other related services;
- Cash collection services;
- Debt recovery services provider;
- Drugs, vitamins and nutritional supplements distribution;
- Detective services provider;
- Direct marketing services provider;
- Pyramid schemes;
- Telemarketing;
- Pawnshop services provider;
- Auctions and related services provider;
- Tobacco and alcohol products distribution
In accordance with internal AML Procedure has clients of two risk categories, i.e., low risk clients and high risk clients. For high risk client EDD must be performed
A high-risk client is someone:
- who is politically exposed person, his/her family member or a close associate;
- who has a prior criminal record known to Website.
SanctionsWebsite is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Website will therefore screen against the relevant sanctions lists in the jurisdictions in which we operate.
Website has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation:
- sanction lists administered by the United States Office of Foreign Assets Control (OFAC),
- the Canadian Government Sanctions List/s;
- the United Nations Security Council Sanctions List (UN);
- the Consolidated List of European Union Financial Sanctions (EU);
- including the List of Specially Designated Nationals and Blocked Persons;
- any other sanctions list.
In addition, Website pays particular attention to entities from countries which are on the list of noncooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.
List of Non-serviced CountriesWebsite does not open accounts and does not provide services to clients from the following countries:
- Islamic Republic of Afghanistan AF
- Republic of Angola AO
- Bosnia and Herzegovina BA
- Republic of Botswana BG
- Commonwealth of The Bahamas BS
- Kingdom of Cambodia CM
- Republic of Burundi BI
- Democratic Republic of the Congo CD
- Central African Republic CF
- Republic of the Congo CG
- People's Democratic Republic of Algeria DZ
- Republic of Ecuador EC
- State of Eritrea ER
- Federal Democratic Republic of Ethiopia ET
- Republic of Ghana GH
- Republic of Guinea GN
- Republic of Guinea-Bissau GW
- Co-operative Republic of Guyana GY
- Republic of Haiti HT
- Republic of Iraq IQ
- Islamic Republic of Iran IR
- Japan JP Republic of Kenya KE
- Democratic People's Republic of Korea KP
- Lebanese Republic LB
- Republic of Liberia LR
- Libya LY
- Republic of the Union of Myanmar MM
- Federal Republic of Nigeria NG
- Islamic Republic of Pakistan PK
- Republic of Serbia RS
- Russian Federation RU
- Republic of the Sudan SD
- Democratic Socialist Republic of Sri Lanka SL
- Federal Republic of Somalia SO
- Republic of South Sudan SS
- Syrian Arab Republic SY
- Republic of Tunisia TN
- Republic of Trinidad and Tobago TT
- Republic of Uganda UG
- United States of America US
- Republic of Vanuatu VU
- Bolivarian Republic of Venezuela VE
- Republic of Yemen YE
- Republic of Zimbabwe ZW
Monitoring for suspicious activityWebsite AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, Website may request information regarding the transactions carried out through the customer’s account opened at Website and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner Website also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.
Multiple Accounts Policy
It is prohibited to have more than one account on our website.
If it is detected that a customer has more than one account, all of the accounts will be temporarily disabled. The customer will be requested to choose which one of his accounts will be active, while the others will stay blocked permanently.
If it is detected that a customer creates multiple accounts in order to overcome the limits set by Zion for a certain payment method, Zion reserves the right to request additional verification from the customer. In case the customer is unable to provide the requested information, Zion will refund the payment to the original sender, while keeping the incoming and outgoing transaction fees if those apply.
List of the Required and Supported Documents:
Some of the following documents might be required during the verification process at Paybis.com
Identity Verification:
- Government issued International Passport
- Government issued Identity Card
- Government issued Driving License
- Selfie with an Identity Document
Address Verification:
- Utility bill or Bank Statement, not older than 6 month
- Paper versions or electronic versions are allowed
- No modifications are allowed to the documents
- Additional Verification Documents:
Photo of Credit Card (in specific cases, only when making a payment with your Debit/Credit Cards)
Selfie with Credit Card (in specific cases, only when making a payment with your Debit/Credit Cards)
Photo with printed or handwritten declaration (in specific cases, for high amounts)
Please note: All required documents should be provided in good quality, all texts should be readable, there should not be any modifications or edits of the document photos, otherwise we would have to reject them and request new copies without modification or in better quality.
Last updated: April 17, 2024