AML / Compliance Notice

1. Our role in the verification process

PREFLOOR LTD carries out its own initial and ongoing compliance verification of counterparties under internal procedures for risk management, prevention of fraud and financial crime, and compliance with the requirements of licensed payment partners.

Verification by PREFLOOR LTD may include the collection and analysis of corporate documents, establishing the ownership structure and beneficial owners, sanctions and PEP screening, adverse media screening, and assessment of the business model, licences, markets of operation and other risk factors.

The necessary documents, information and verification results may be passed to the relevant licensed payment partner for its own independent review.

The licensed payment partner assesses the counterparty independently, may request additional documents and information, and takes the final decision on connection and on the provision of payment services.

Successful verification by PREFLOOR LTD does not guarantee subsequent approval by a licensed payment partner.

2. Before the relationship begins

Before the relationship begins, each counterparty completes the PREFLOOR LTD KYB questionnaire and provides the documents and information required in light of the nature of its activity and its risk level, including:

• corporate documents, including the certificate of incorporation, constitutional documents, and details of the registered office, directors, shareholders and beneficial owners;
• identification documents of the director or other authorised person acting on behalf of the company;
• information on the ownership and control structure;
• information on shareholders and ultimate beneficial owners holding, directly or indirectly, 10% or more, or otherwise exercising significant control;
• a description of the business model, goods or services;
• information on expected volumes, currencies, countries, payment corridors and payment methods used;
• licences, permissions and registrations, where required by applicable law;
• an operating website, including the applicable terms of use, refund policy and company information;
• other documents and information that PREFLOOR LTD or the relevant licensed payment partner reasonably considers necessary for due diligence.

PREFLOOR LTD may request certified copies, translation, notarisation, apostille or other confirmation of authenticity where this is necessary given the jurisdiction, the nature of the document, the risk level or the requirements of the licensed payment partner.

3. Screening

PREFLOOR LTD screens the relevant natural and legal persons. Screening may include:

• sanctions lists;
• PEP screening;
• adverse media;
• fraud and other compliance-related checks.

Depending on the circumstances and the risk level, screening may extend to:

• directors;
• shareholders;
• beneficial owners;
• controlling persons;
• the company itself;
• other relevant participants in the business model.

Screening is performed both at initial onboarding and during the business relationship.

Automated screening tools may be used to identify matches, alerts and other risk indicators. Such results do not in themselves amount to an automatic final refusal and are subject to further assessment where necessary.

4. Risk-based approach

The depth and scope of due diligence depend on the risk level of the individual counterparty.

In assessing risk, PREFLOOR LTD may take into account, among other things:

• the type of activity;
• the countries and markets of operation;
• the ownership and control structure;
• the transparency of the corporate structure;
• the presence and nature of licensing;
• the payment methods used;
• the expected volumes and nature of transactions;
• chargeback, refund and fraud risk;
• reputational and sanctions risk;
• the requirements of the relevant licensed payment partner.

For higher-risk counterparties, PREFLOOR LTD may apply enhanced due diligence, request additional documents including Source of Funds and/or Source of Wealth, and carry out more frequent ongoing monitoring.

5. Ongoing monitoring

During the business relationship, PREFLOOR LTD may carry out ongoing monitoring, including:

• periodic review of the counterparty compliance file;
• repeat sanctions, PEP and adverse media screening;
• reassessment of risk where the business model, ownership, control, licensing status, markets of operation or volumes change;
• analysis of information about activity that may differ materially from the declared business model;
• requests for updated documents and information;
• other measures reasonably necessary to manage compliance, fraud, sanctions and other risks.

The counterparty must notify PREFLOOR LTD without undue delay of material changes to its ownership or control structure, licensing status, business model, jurisdictions of operation or other circumstances that may affect its risk profile, within the period set by the relevant agreement or other applicable terms.

6. Transfer of data to licensed partners

For the purposes of connection and continued service, PREFLOOR LTD may transfer to the relevant licensed payment partner the documents and information collected through KYB/KYC, due diligence, screening and ongoing monitoring.

Such transfer may include, as necessary:

• corporate documents;
• details of directors, shareholders and beneficial owners;
• identification documents;
• screening results;
• information on the business model and licensing;
• Source of Funds / Source of Wealth;
• transactional and other information necessary to assess risk and provide the relevant services.

The licensed payment partner may carry out its own independent review and is not obliged to rely solely on the results of the PREFLOOR LTD review.

The transfer and processing of personal data is carried out in accordance with applicable data protection law and the Privacy Policy of PREFLOOR LTD.

7. When we may refuse or suspend the relationship

Depending on the nature and level of risk, PREFLOOR LTD may:

• request additional documents or explanations;
• postpone or refuse onboarding;
• impose additional conditions or restrictions;
• suspend the interaction;
• terminate the business relationship.

Such measures may be applied, in particular, where:

• the activity of the counterparty falls into a prohibited or unacceptable category;
• the ownership structure or the beneficial owners cannot be established with sufficient certainty;
• the required documents or information are not provided;
• applicable sanctions restrictions or unacceptable sanctions risk are identified;
• the information provided is false, incomplete, contradictory or misleading;
• the actual activity differs materially from the declared activity;
• the level of AML, fraud, chargeback, regulatory, reputational or other risk becomes unacceptable;
• the relevant licensed payment partner refuses connection or continued service.

PREFLOOR LTD is not obliged to disclose the detailed reasons for a decision where such disclosure is restricted by applicable law, by the requirements of competent authorities or of a licensed payment partner, or where it may affect the effectiveness of compliance measures.

8. Mutual due diligence

As part of reasonable mutual due diligence, PREFLOOR LTD may on request provide corporate and compliance documents about itself that are necessary for review by a counterparty or a licensed payment partner.

The scope of the information provided is determined in light of the purpose of the request, confidentiality requirements, data protection and other applicable restrictions.

9. Record retention

PREFLOOR LTD retains documents and information obtained through KYB/KYC, due diligence, screening and ongoing monitoring for as long as necessary for the relevant compliance, contractual, fraud prevention and other lawful purposes, and for the periods provided by applicable law or by the reasonable requirements of licensed payment partners.

On expiry of the applicable retention period, data is deleted, anonymised or otherwise removed from active processing, unless further retention is required by law or to protect the legitimate interests of PREFLOOR LTD.

10. Contact

To request the KYB questionnaire, provide updated documents or raise a compliance question, contact us:

PREFLOOR LTD
Giannou Kranidioti & Pargas 9,
Floor 1, Flat/Office 102,
1065 Nicosia, Cyprus

E-mail: business@prefloorltd.com