AML Notice
This notice describes how we assess and monitor the businesses we work with. It is a summary for counterparties, not our internal policy.
Who we are. PREFLOOR LTD supplies payment orchestration technology and acts as an agent introducing merchants to licensed payment providers. We route transactions, provide reporting and support. We do not hold, safeguard or settle funds, we do not issue payment instruments, and we do not operate accounts for merchants or their customers. Settlement is carried out by licensed payment institutions, electronic money institutions and acquirers under their own agreements with the merchant.
1. Our position in the chain
Because we do not hold or settle funds, we are not the regulated party for the payment itself. The licensed partner performs its own regulatory due diligence and applies its own transaction monitoring, and its assessment is independent of ours. Our checks come first and are a condition of us working with you at all; passing ours does not guarantee that a partner will accept you.
2. Before we start
Every counterparty completes our KYB questionnaire and provides:
- corporate documents: certificate of incorporation, memorandum and articles, registered office, registers of directors and shareholders, register of beneficial owners;
- identification of the director signing on behalf of the company, and proof of address;
- identification of shareholders and ultimate beneficial owners holding 10% or more;
- a description of the business model, expected volumes, currencies, corridors and payment methods;
- licences or registrations where the activity requires them;
- a working website with terms, refund policy and company details.
Documents in another language must come with a certified translation. Corporate documents must be certified copies, and an apostille may be requested.
3. Screening
Directors, shareholders from 10% and beneficial owners are screened against sanctions lists, politically exposed person data and adverse media. Screening is repeated during the relationship, not only at onboarding. A match is reviewed by a person; it is not an automatic decline, and a decision is never taken by software alone.
4. Risk-based approach
The depth of due diligence depends on the risk presented by the counterparty: its vertical, its markets, its ownership structure, the transparency of its corporate chain, and the payment methods requested. Higher risk means more evidence, including source of wealth for beneficial owners, and more frequent review.
5. Ongoing monitoring
- periodic review of the file, more often for higher-risk counterparties;
- re-screening of the individuals named in the file;
- review when the business model, ownership, markets or volumes change materially;
- attention to patterns inconsistent with the declared business.
You must tell us in writing within 14 days of any change to ownership, control, licensing status, or the nature of the business.
6. When we decline or stop
We decline or terminate where a counterparty falls within our prohibited activities, where ownership cannot be established, where required documents are not provided, where a sanctions nexus exists, or where information given to us proves to be false. We are not obliged to give reasons, and in some circumstances we are legally prevented from doing so.
7. Reciprocity
We provide the same categories of document about ourselves that we ask of you, on request: corporate documents of PREFLOOR LTD, our register of beneficial owners, and identification of our director.
8. Contact
To request the KYB questionnaire or to raise a compliance question, write to business@prefloorltd.com.