Compliance
AML / CFT Policy
1. What this policy is for
Loco Pay services are for lawful personal and business payments. Identity checks, transaction monitoring, and reports where the law requires them are used to prevent the services from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful purposes.
2. Who it covers
This policy applies to personal and business customers, to the owners, controllers, authorised users, and cardholders of a business, and to the people and partners who carry out identity checks and transactions for Loco Pay. It applies before an account is opened, while it is used, and for as long as records must be kept after the relationship ends.
3. Identity checks
Before an account is opened and before a feature that can move funds is used, we confirm the customer’s identity. For a personal customer this usually includes:
- legal name, date of birth, and nationality;
- a government photo identity document, checked against a likeness capture;
- residential address, and a mobile number and email the customer controls;
- the purpose of the account and the expected use;
- where the amount or the risk requires it, an explanation of the source of funds.
Checks are repeated when a document expires, when use of the account changes, or when a payment needs more explanation. A card is not issued, and a withdrawal or other checked operation is not completed, while identity remains unverified.
4. Business customers
A business customer provides the company name, registration details, business address, and a description of its business, and identifies the people who control the company and who are authorised to operate the account. Anyone who can start a payment or use a card is also checked. An application is not accepted where ownership or the real business cannot be explained.
5. Higher-risk reviews
Risk is assessed by customer, country, product, and how the account is used. In ordinary cases, identity and the purpose of use are enough. Where the risk is higher, we ask about the source of funds and the background of a payment, and we may ask for an invoice, contract, or other document. Higher-risk situations include a politically exposed person and people closely connected with one, a higher-risk country or territory, activity that does not match ordinary use, and business ownership that is complex or has recently changed. If the additional information does not explain the activity, we may decline the customer or the payment.
6. Transaction monitoring
While an account is open, we look for unusual activity, such as funds arriving and leaving immediately, payments split to stay under a threshold, a sudden change of country or recipient, card use that does not fit the cardholder, and continued activity after requests for information have been refused. Staff review alerts and may ask you to explain a payment. The detection rules are not published.
7. Sanctions screening
Customers, the people who control a business, authorised users, cardholders, and the parties connected with a payment are screened against applicable sanctions lists, including United Nations lists and lists published by other authorities that apply to the payment. Screening is done at onboarding, when important information changes, and when a payment is made, and the customer base is rescreened periodically. We do not open an account or process a payment for a person or entity we are prohibited from serving. Countries and territories subject to comprehensive sanctions are outside the service.
8. Activity we do not support
We do not provide the service for money laundering, terrorist financing, fraud, or the proceeds of crime; for attempts to evade sanctions through another person; for an unlicensed money business; for a false identity or a false purpose of payment; for moving funds for an undisclosed third party; or for a request for a payment or a card before identity checks are complete.
9. What we ask of customers
Please give true and complete identity and transaction information, and explain the purpose or source of funds when we ask about a payment. Do not let another person use your account. The account can continue only if this information is provided.
10. Reports and holds
Where a matter must be reported, we report it to the competent authority and, where needed, tell the partner handling that payment. The payment may be held while the matter is reviewed. Where the law prohibits telling a customer about an investigation, we cannot explain the specific reason. Whether the relationship continues is decided when the review is complete.
11. Records
Identity records, transaction records sufficient to reconstruct a payment, and the outcome of a review are kept for at least five years after the relationship ends or the transaction occurs. A longer period required by law or by a partner arrangement is followed. Records are kept so that they can be produced promptly to an authority that is entitled to request them.
12. How this is carried out
The company designates a compliance officer to handle matters that may need to be reported and to liaise with authorities and partners. People who handle customer information or review transactions are trained before they start and regularly after that. Card, settlement, and screening partners work under written arrangements that set out identity checks, protection of information, and cooperation on reviews.
13. Updates and contact
When the law or the business changes, we update this policy and publish the current version on this page. Questions about this policy can be sent to service@locopay.io.