Anti-Money Laundering (AML) Policy

Effective Date: September 26, 2023


1. Introduction

PayMe by vPin is committed to maintaining the highest standards of ethical conduct and legal compliance. This Anti-Money Laundering (AML) Policy outlines our commitment to preventing money laundering and complying with relevant AML laws and regulations.


2. Purpose

This AML Policy is designed to:

  • Prevent the use of PayMe by vPin for money laundering activities.
  • Detect and report suspicious transactions to the appropriate authorities.
  • Ensure compliance with applicable AML laws and regulations.
  • Establish internal controls and procedures for AML compliance.


3. AML Compliance Officer

PayMe by vPin shall designate a qualified AML Compliance Officer responsible for implementing and overseeing AML procedures and compliance. The Compliance Officer shall have the authority to:

  • Develop, implement, and update AML policies and procedures.
  • Monitor transactions and customer accounts for suspicious activity.
  • Report suspicious transactions to appropriate authorities.


4. Customer Due Diligence (CDD)

To mitigate the risk of money laundering, PayMe by vPin shall implement a robust Customer Due Diligence (CDD) process, which includes:

  • Verifying the identity of customers.
  • Collecting and maintaining customer identification records.
  • Monitoring and updating customer information as required by law.


5. Suspicious Activity Monitoring

PayMe by vPin shall implement monitoring systems and controls to detect suspicious activities. This includes:

  • Identifying red flags and unusual patterns of transactions.
  • Conducting ongoing monitoring of customer accounts.
  • Reporting suspicious transactions to the relevant authorities as required by law.


6. Record Keeping

PayMe by vPin shall maintain accurate records of all customer transactions and due diligence efforts as required by applicable AML laws and regulations.


7. Training and Awareness

Regular training and awareness programs shall be conducted for employees to ensure they understand the importance of AML compliance and their role in preventing money laundering.


8. Reporting Obligations

PayMe by vPin shall promptly report any suspicious transactions to the appropriate authorities as required by law. The Compliance Officer will oversee this reporting process.


9. Third-Party Relationships

Due diligence shall be conducted on third-party service providers to ensure they adhere to AML regulations. PayMe by vPin shall not engage in business relationships that may expose us to AML risks.


10. Sanctions Compliance

PayMe by vPin shall comply with all relevant international sanctions laws, including the United States Office of Foreign Assets Control (OFAC) regulations.


11. Penalties for Non-Compliance

Non-compliance with this AML Policy may result in disciplinary action, including termination of employment or legal action.


12. Updates and Review

This AML Policy shall be reviewed periodically to ensure its effectiveness and compliance with changing AML laws and regulations.


13. Contact Information

For questions or concerns regarding this AML Policy, please contact our AML Compliance Officer at

By using PayMe by vPin, you acknowledge and agree to comply with this Anti-Money Laundering Policy. Failure to adhere to this policy may result in the termination of your account and legal consequences.