AML and KYC Practices

The detection and prevention of money laundering and other forms of corruption is a constantly evolving struggle. In recent years, regulators have been working to fight financial crimes through introducing and enacting legislation. Some recent examples of this include the Anti-Money Laundering (AML) Act of 2020 (passed) and the ENABLERS Act (introduced).

Despite this, criminals are continuously learning and developing new ways to slip through the cracks. Acupay believes that we must play our part to help however we can when it is under our control. That is why Acupay has policies and procedures to identify and prevent the improper use of our services to enable money laundering and other illicit activities.

For example, Acupay’s Anti-Money Laundering and Know Your Client (AML/KYC) Programme Handbook explains the responsibilities of employees for the detection, prevention, and reporting of various forms of corruption and criminal activity. It also gives a brief overview of relevant laws and regulations as well as a description of Acupay’s Client Due Diligence (CDD) and Government Sanction List Screening Procedures. Each year, Acupay’s employees are required to complete training and testing to make sure they are informed and kept up to date.

Part of Acupay’s screening procedures include automated checks of all beneficial owner records submitted through the Acupay System against lists maintained by the US Office of Foreign Asset Control (OFAC) and EU Common Foreign and Security Policy (CFSP). Potential hits are reviewed by our Operations team, with suspected positive hits reported to our Risk and Compliance Officer for further review and, if required, reporting.

Acupay also has Client Risk Assessment Procedures that it uses to consider the potential risks of engaging with a client. Acupay performs standard CDD reviews by collecting and inspecting completed questionnaires and client documentation with the possibility of enhanced due diligence (EDD) being required if determined it is appropriate based on the risks faced. Included in these reviews are examinations of the client’s country of residence and operations against several government sanction lists such as US OFAC and UK OFSI and global risk lists like the Corruption Perception Index (CPI), Global Slavery Index (GSI), Financial Action Task Force’s (FATF) list of elevated risk and other monitored jurisdictions. Acupay aims to understand the risks involved and determine whether they need to be mitigated or avoided altogether. By doing these checks as part of its risk assessment process, Acupay plays its role in the global effort to prevent money laundering and other forms of corruption.