AML & KYC Policy

1. Definitions and General Principles

 

Money laundering refers to the process of concealing the illicit origin of proceeds derived from criminal activities by integrating such funds into the financial system through cash or seemingly legitimate transactions.

Paynbuy Technology (“Paynbuy”, “Company”, “we”, “us”) is committed to providing secure, transparent, and legally compliant services. In this context, the Company fully implements Anti-Money Laundering (AML) and Know Your Customer (KYC) measures to prevent money laundering, terrorist financing, fraud, and other financial crimes.

This Anti-Money Laundering and Know Your Customer Policy (“AML & KYC Policy”) sets out the procedures, controls, and principles adopted by the Company.

 

2. Purpose and Scope

 

The purpose of this AML & KYC Policy is to apply a risk-based approach to customers, transactions, and services; prevent money laundering and terrorist financing; ensure employee awareness and compliance; and demonstrate that Company activities are conducted in accordance with applicable laws and regulations.

This Policy applies to all users (individuals and legal entities) registered on www.epinpay.com, all transactions conducted through the platform, and all employees, contractors, and relevant business processes.

By using the platform, users are deemed to have accepted this AML & KYC Policy.

 

3. Regulatory and Legal Framework

 

This Policy has been prepared in accordance with applicable United Arab Emirates (UAE) laws and regulations on anti-money laundering and counter-terrorist financing, guidance issued by competent regulatory authorities, international standards published by the Financial Action Task Force (FATF), and compliance requirements of banks, payment service providers, and business partners.

 

4. Platform Business Model

 

Epinpay operates as a peer-to-peer (P2P) digital marketplace facilitating the sale of digital products.

For payment and transaction processing purposes, Paynbuy acts as the Merchant of Record and is responsible for payment collection, refunds, chargebacks, and compliance obligations associated with transactions processed on the platform.

 

5. Core AML Principles

 

The Company adopts the following core AML principles:

Not establishing business relationships with individuals or entities linked to criminal or terrorist activities;
Not processing or facilitating transactions derived from criminal or terrorist sources;
Preventing the misuse of the platform for money laundering or terrorist financing;
Identifying, monitoring, and reporting suspicious activities in accordance with applicable regulations.

 

6. Risk-Based Approach and Risk Assessment

 

Paynbuy applies a risk-based approach to AML and KYC compliance. Risk assessments consider customer profile, transaction type, transaction amount and frequency, geographic location, and behavioral and technical indicators.

High-risk indicators may include high-value or aggregated transactions, unusual or economically unjustifiable activity, doubts regarding customer information accuracy, transactions conducted for unidentified third parties, and circumstances requiring suspicious activity reporting.

 

7. Know Your Customer (KYC) Procedures

 

7.1 Sellers
All sellers must complete full identity and/or business verification (KYC/KYB) before being allowed to sell on the platform.

The Company may request government-issued identification documents, company incorporation and authorization documents, Ultimate Beneficial Owner (UBO) information, and address verification documents.

7.2 Buyers
Buyers are subject to a risk-based KYC framework. Based on transaction data, the Company may request additional information or documentation. Transactions may be delayed, restricted, or declined where necessary.

The Company reserves the right to request updated or additional information even if a customer has been previously verified.

 

8. Sanctions and Politically Exposed Persons (PEP) Screening

 

The Company screens customers and sellers against sanctions lists, terrorist watchlists, and Politically Exposed Persons (PEP) databases. Enhanced Due Diligence (EDD) is applied where required.

 

9. Transaction Monitoring and Ongoing Due Diligence

 

The Company conducts continuous monitoring of transactions, including transaction velocity, unusual patterns, country/IP mismatches, and chargeback or fraud indicators.

 

10. Suspicious Activity and Reporting

 

Suspicious activities are subject to internal review and may be reported to competent authorities in accordance with applicable laws and regulations.

 

11. Account Suspension and Termination

 

The Company may reject transactions or suspend or terminate accounts where there is suspicion of financial crime or policy violations.

 

12. Record Keeping

 

The Company securely retains customer identification data, transaction records, and compliance assessments in accordance with applicable legal and regulatory requirements.

 

13. AML Compliance Officer

 

An AML Compliance Officer is appointed to oversee the implementation and effectiveness of this Policy.

 

14. Training, Review, and Internal Controls

 

Employees receive regular AML and KYC training. This Policy is reviewed periodically to ensure alignment with regulatory developments and operational risks.

 

15. Contact

 

For questions regarding this AML & KYC Policy:
Email: [email protected]

Update : 07/Jan/2026