Our AML Commitment
FalconPay is committed to preventing money laundering, terrorist financing, and financial crime in full alignment with the Financial Action Task Force (FATF) recommendations and the specific AML/CFT obligations that apply in each jurisdiction where we operate or serve merchants. Our controls are risk-based, independently audited, and maintained as an active internal programme — not a set-and-forget checklist.
Customer Due Diligence (CDD)
We perform risk-based customer due diligence on every merchant before onboarding, including:
- Identity verification of the corporate entity and its directors.
- Beneficial ownership identification at the 25%-or-greater threshold, with enhanced disclosure where risk factors are present.
- Verification of operational licences where the vertical requires one (gaming, financial services, crypto).
- Screening against international sanctions lists (OFAC, UN, EU, UK HMT, local lists) and politically exposed person (PEP) databases.
- Adverse media screening for reputational and financial-crime risk.
- Source-of-funds and source-of-wealth assessment where triggered by risk profile.
Enhanced Due Diligence (EDD)
Higher-risk relationships — PEPs, merchants in high-risk jurisdictions, specific verticals (unlicensed crypto, high-volume gaming in transitional regimes), and complex ownership structures — receive enhanced due diligence: deeper documentary review, senior management approval to onboard, ongoing periodic refresh at shorter intervals, and in some cases on-site verification.
Ongoing Transaction Monitoring
All transactions are subject to automated rule-based and behavioural monitoring for patterns consistent with money laundering, structuring, fraud, and sanctions evasion. Alerts are triaged by our compliance analysts, escalated where appropriate, and either cleared with documentation or filed as suspicious activity. Monitoring parameters are tuned per-merchant based on expected business profile and reviewed continuously.
Sanctions Screening
We screen every transaction in real time against consolidated sanctions lists before processing. Any match or likely match results in immediate hold, escalation to the sanctions officer, and — where confirmed — rejection of the transaction and filing of the appropriate regulatory report. Screening is applied to senders, receivers, and intermediary parties where visible.
Suspicious Activity Reporting
Transactions or patterns that meet the threshold for suspicion are reported to the relevant financial intelligence units (FIUs) in the applicable jurisdiction within the timeframe required by local law. Tipping-off rules are strictly observed — we do not disclose to merchants or counterparties that a SAR has been filed.
Record Keeping
KYC records, transaction records, and compliance investigation files are retained for the period required by applicable law — typically 5 to 10 years after termination of the merchant relationship, depending on jurisdiction. Records are stored securely and available for lawful regulatory inspection.
Training and Governance
All staff — not only compliance personnel — receive AML training on joining and annually thereafter. The AML programme is owned by a designated Money Laundering Reporting Officer (MLRO) with direct reporting line to senior management and the board. External independent AML reviews are commissioned at least annually.
Reporting and Escalation
Merchants, staff, and third parties can report suspected financial-crime activity related to our service confidentially at [email protected]. Whistle-blower protections apply per applicable local law.
Compliance enquiries: [email protected]