Anti-Money Laundering (AML) Policy

Last Updated Dec 22, 2024

1. Introduction

XenPay is committed to preventing money laundering and the financing of terrorism in accordance with applicable laws, including those of Portugal and international standards. This Anti-Money Laundering (AML) Policy outlines the steps we take to detect and prevent money laundering activities on our platform and to comply with the legal obligations imposed by regulators and financial authorities.

2. Purpose of the AML Policy

The purpose of this policy is to establish and maintain effective controls to detect, prevent, and report potential money laundering and terrorist financing activities, as well as to ensure that XenPay complies with the Anti-Money Laundering (AML) regulations and requirements.

3. Customer Due Diligence (CDD) and Know Your Customer (KYC)

XenPay implements Customer Due Diligence (CDD) procedures as part of our commitment to AML compliance. This includes identifying and verifying the identity of customers who engage with our services, particularly those who engage in significant transactions or exhibit suspicious activity.

We perform Know Your Customer (KYC) checks to ensure that we only provide services to legitimate customers and to prevent the misuse of our platform for illegal activities.

  • Verification of Identity : Users are required to provide personal identification information, including documents such as a passport, national ID, or driver’s license.
  • Enhanced Due Diligence (EDD) : For customers engaging in high-risk transactions, we may implement additional measures to verify their identity and source of funds.

4. Monitoring of Transactions

We actively monitor all transactions on our platform for suspicious activities. This includes:

  • Large or unusual transactions, especially those that appear inconsistent with the customer's profile.
  • Transactions that involve high-risk jurisdictions or unverified counterparties
  • Transactions that suggest layering or structuring to evade detection.

If a suspicious activity is detected, XenPay reserves the right to freeze or block the account and report the matter to the relevant authorities.

5. Reporting Suspicious Activity

XenPay is obligated to report suspicious transactions to the relevant financial authorities or regulators in Portugal and other jurisdictions as required by law. This includes transactions that may involve money laundering, terrorist financing, or other illegal activities.