Anti-Money Laundering (AML), Know Your Customer (KYC) & Financial Crime Policy
Effective Date: 07/07/2026
1. Introduction
Octalas Pay is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. We have implemented robust Anti-Money Laundering (“AML”), Counter-Terrorist Financing (“CTF”), Know Your Customer (“KYC”), sanctions compliance, and financial crime prevention procedures designed to protect our customers, partners, and the wider financial system.
This Policy outlines the principles and controls that govern our approach to preventing the misuse of our platform for money laundering, terrorist financing, fraud, sanctions evasion, bribery, corruption, or other financial crimes.
2. Our Commitment
Octalas Pay is committed to:
- Preventing financial crime.
- Maintaining effective customer due diligence procedures.
- Complying with applicable AML, CTF, sanctions, and financial crime legislation.
- Cooperating with competent regulatory and law enforcement authorities.
- Protecting the integrity of the global financial system.
3. Risk-Based Approach
We apply a risk-based approach to customer onboarding and ongoing monitoring.
Risk assessments may consider:
- Customer type
- Business activity
- Industry sector
- Geographic location
- Ownership structure
- Transaction behaviour
- Source of funds
- Delivery channels
- Regulatory exposure
Higher-risk relationships may be subject to Enhanced Due Diligence (EDD).
4. Customer Identification (KYC)
Before providing services, customers may be required to provide:
Individuals
- Full legal name
- Date of birth
- Residential address
- Government-issued identification
- Contact details
Businesses
- Company registration documents
- Registered address
- Directors
- Ultimate Beneficial Owners (UBOs)
- Ownership structure
- Nature of business
- Bank account verification
- Tax identification numbers
Additional documentation may be requested where necessary.
5. Customer Due Diligence (CDD)
Customer Due Diligence may include:
- Identity verification
- Document authentication
- Business verification
- Beneficial ownership verification
- Adverse media screening
- Politically Exposed Person (PEP) screening
- Sanctions screening
- Source of funds verification
- Source of wealth verification (where applicable)
Verification requirements vary according to customer risk.
6. Enhanced Due Diligence (EDD)
Enhanced Due Diligence may be required for:
- Politically Exposed Persons (PEPs)
- High-risk jurisdictions
- Complex ownership structures
- High-value transactions
- High-risk industries
- Cross-border payment activity
- Customers presenting elevated financial crime risks
EDD may include additional documentation, management approval, and increased monitoring.
7. Ongoing Monitoring
Customer relationships are monitored throughout their lifecycle.
Monitoring may include:
- Transaction analysis
- Behavioural monitoring
- Risk profile reviews
- Sanctions rescreening
- Trigger event reviews
- Periodic KYC refreshes
Customers may be asked to update information periodically.
8. Sanctions Compliance
Octalas Pay screens customers and transactions against applicable sanctions lists, including those issued by:
- United Nations (UN)
- European Union (EU)
- United Kingdom (OFSI)
- United States (OFAC)
- Other relevant authorities where applicable
Transactions involving sanctioned individuals, entities, or jurisdictions may be declined, frozen, or reported where required by law.
9. Politically Exposed Persons (PEPs)
We identify customers who are:
- Politically Exposed Persons
- Family members of PEPs
- Close associates of PEPs
PEPs are not automatically prohibited from using our services but may be subject to Enhanced Due Diligence and ongoing monitoring.
10. Fraud Prevention
Octalas Pay employs a combination of automated systems and risk controls designed to detect and prevent:
- Identity fraud
- Account takeover
- Payment fraud
- Card fraud
- Merchant fraud
- Synthetic identity fraud
- Money mule activity
- Transaction laundering
Suspicious activity may result in delayed processing, enhanced verification, account suspension, or reporting to the relevant authorities.
11. Suspicious Activity
Where suspicious activity is identified, Octalas Pay may:
- Request additional information
- Delay transactions
- Suspend accounts
- Decline transactions
- Terminate customer relationships
- Report activity to competent authorities where legally required
We may be prohibited by law from informing customers where such reports have been made.
12. Record Keeping
We retain customer identification records, transaction records, and compliance documentation for the periods required under applicable law and regulatory obligations.
13. Third-Party Verification
To support our compliance programme, Octalas Pay may utilise trusted third-party providers for:
- Identity verification
- Business verification
- Document authentication
- AML screening
- Sanctions screening
- Fraud detection
- Ongoing monitoring
14. Employee Training
Employees involved in customer onboarding, compliance, operations, and risk management receive appropriate training relating to:
- AML obligations
- Financial crime risks
- Fraud prevention
- Data protection
- Regulatory compliance
- Suspicious activity reporting
15. Regulatory Cooperation
Octalas Pay will cooperate with competent regulatory authorities, law enforcement agencies, and authorised financial institutions where disclosure is required by law or regulation.
16. Policy Updates
This Policy may be updated periodically to reflect changes in applicable laws, regulations, industry standards, or operational practices.
The latest version will always be published on our website.
17. Contact
For compliance-related enquiries, please contact:
Compliance Department
Octalas Pay
Email: compliance@octalaspay.com
