Anti-Money-Laundering policy

In terms of law, money laundering means legalizing the proceeds of crime, i.e. actions that conceal the source of funds in order to make their nature lawful.

Anti-money laundering (AML) incorporates a complex of measures aimed at prevention of use of the financial system of the country or any specific financial institution for money laundering or terrorist financing. Such measures and instruments are worked out and implemented by international and national institutions, banking and business community.

STICPAY collects identification data of every Client, as well as IP addresses, online activity, communications and ,in general, all transactions carried out by the Client.

STICPAY tracks, including auto-monitoring and auto-controlling, suspicious activities of the clients and transactions executed under unusual conditions. This includes, but not limited to, transactions that do not make economic sense, unexplained large transactions, transactions involving unidentified parties, investments related transactions of unclear nature. STICPAY reserves the right to ask supporting documentation for the suspicious transactions.

Enhanced Due Diligence is exercised on high turnover customers and/or potential suspicious customers/transactions.

Purpose of the transaction is established where applicable.

STICPAY improves its AML procedures continuously to monitor unlawful financial schemes.

STICPAY reserves the right to refuse to process a transaction at any stage, when we believe that the transaction is associated with money laundering or other criminal activity.

STICPAY complies with the legal requirements of the Republic of Panama for anti-money laundering. In cases set forth in the relevant legal enactments, we co-operates with officials and government institutions of the Republic of Panama, as well as other countries.

Anti-Money Laundering Policy

Money laundering is an act of engaging in such financial transactions where money gained from illegal activities is converted into money which appears to be gained through legal means. The objective of this act is to conceal the illegitimate identity of any monetary instrument including cash amounts. That is why national and international laws make it illegal for STICPAY and its employees to be knowingly or recklessly engaged in any activity related to such illegally gained capital.

Implemented Procedures

STICPAY implements a strong anti-laundering policy to ensure that its customers will be identified for such suspicions up to a certain standard to minimize the procedural complications for genuine and legitimate customers. In order to fulfil its commitment to provide full assistance to governments combating against such illegal financial transactions, STICPAY has developed a technologically advanced and reliable electronic system, which completely verifies its client identity and is able to maintain a detailed record of all previous financial transactions. STICPAY makes sure to track all suspicious activities and report any these to the relevant law enforcement bodies. That is why complete legal protection is provided to clients who share confidential financial data with the company. To discourage money laundering and related illegal activities STICPAY does not deal in cash transactions whether to deposit or withdraw funds. Our company reserves the right to suspend any transaction where it finds even a suspicion of money laundering.

Compliance Regime

Like other financial institutions STICPAY has also set up a compliance regime in order to fulfil its formal legal requirements. This includes the appointment of a Compliance Officer, policy making, regular review of their implementation and impact and professional compliance training to regime staff members. STICPAY also ensures regular updating of its electronic systems to modern rules and regulations developed for more sophisticated checks to trace money laundering and other criminal financial practices. Professional training is provided for STICPAY’s employees to trace such illegal activities and to use modern technological systems, which constitutes part of STICPAY’s essential policies.

Additional Disclosure

Identification

In order to fully comply with anti-money laundering laws, STICPAY demands two kinds of documents for the satisfactory identification and verification of customers' account. The first one is a government issued document with a photo of the customer on it. It can be a passport, driving license or regular ID card which must be issued by the government. The second one is any bill or document with the complete name and address information on it. It can be a utility bill, bank statement, affidavit or any other type of bill which contains the correct personal information (name and address). The proof of address must not be more than 3 months old. Moreover, STICPAY requires an electronic signed application form submission. Customers are also required to inform STICPAY if there are any changes to their personal information. In case documents are in a non-western language, they must first be translated into English by any official translator and this translated copy must be duly signed and stamped by that translator and submitted along with other related documents and clients' photo on it

Deposits and Withdrawals

In case of money deposits the sender name must match the name of customer present in STICPAY record. No third party mediation is allowed in this case so Mr. A cannot deposit money from his name for Mr. B. Similarly, in case of a money withdrawal, the recipient’s name must match the name of the account holder they are withdrawing money from. If the transaction is online money, then funds will only be withdrawn through same online transfer system to the same account from where it has been transferred.