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Paytia Limited is committed to preventing its services from being used for money

laundering, terrorist financing, or other financial crimes. This Anti-Money

Laundering (AML) Compliance Policy outlines the procedures and controls in place

to ensure compliance with applicable laws and regulations, including but not

limited to the UK Money Laundering Regulations 2017, the Proceeds of Crime Act

2002, and guidance from the Financial Conduct Authority (FCA).

2. Purpose

The purpose of this policy is to:

• Establish Paytia's commitment to AML compliance.

• Prevent the use of Paytia's services for illicit financial activities.

• Define procedures for identifying and mitigating money laundering risks.

• Ensure compliance with legal and regulatory requirements.

3. Scope

This policy applies to all employees, contractors, agents, and partners of Paytia

Limited. It covers all aspects of Paytia’s operations, including customer onboarding,

transaction monitoring, and reporting of suspicious activities.

4. AML Compliance Officer

Paytia has designated an AML Compliance Officer (AMLCO) responsible for:

• Overseeing AML policies and procedures.

• Ensuring compliance with regulatory requirements.

• Monitoring transactions and reporting suspicious activity.

• Providing staff training on AML requirements.

• Liaising with regulatory authorities as necessary.

Designated AML compliance officer: Craig Marston (CTO)

5. Customer Due Diligence (CDD)

Paytia implements robust Customer Due Diligence (CDD) procedures, including:

• Know Your Customer (KYC): Verifying the identity of customers before

providing services.

 Enhanced Due Diligence (EDD): Applying additional scrutiny to high-risk

customers and transactions.

• Ongoing Monitoring: Continuously monitoring customer transactions for

unusual or suspicious activities.

5.1. Identity Verification

Customers must provide valid identification documents, such as:

• Government-issued ID (passport, driving licence, or national ID card).

• Proof of address (utility bill or bank statement no older than three months).

• Business registration details (for corporate clients).

5.2. Risk-Based Approach

Paytia employs a risk-based approach to AML compliance, classifying customers

into low, medium, and high-risk categories based on factors such as:

• Nature and purpose of the business relationship.

• Transaction patterns and volume.

• Geographic risk (e.g., customers from high-risk jurisdictions identified by

FATF).

6. Transaction Monitoring and Reporting

6.1. Suspicious Activity Detection

Paytia’s transaction monitoring system detects potentially suspicious activities,

including:

• Unusual transaction volumes or frequency.

• Transactions inconsistent with a customer’s profile.

• Multiple transactions just below regulatory reporting thresholds.

6.2. Reporting Suspicious Activity

If suspicious activity is detected, Paytia will:

• Conduct an internal review.

• Report the activity to the National Crime Agency (NCA) via a Suspicious

Activity Report (SAR), if required.

• Cooperate with regulatory authorities in any investigation.

7. Record Keeping

Paytia maintains AML-related records for at least five years, including:

4 | P a g e• Customer identification documents.

• Transaction records.

• Internal reviews and reports of suspicious activities.

8. Staff Training and Awareness

All employees undergo regular AML training, which includes:

• Recognising money laundering risks.

• Identifying and reporting suspicious transactions.

• Understanding regulatory requirements and internal procedures.

9. Compliance Reviews and Audits

Paytia conducts regular internal and external audits to assess compliance with

AML policies. The AMLCO ensures timely updates to policies based on regulatory

changes and audit findings.

10. Consequences of Non-Compliance

Failure to comply with AML regulations may result in disciplinary action, regulatory

penalties, and legal consequences. Paytia maintains a 

zero-tolerance approach

to non-compliance.