1. OBJECTIVE OF THE AML POLICY
PayWayler LTD is required to comply with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations in its operations. All employees are committed to maintaining the highest AML and Know Your Customer (KYC) standards to ensure that our services are not used to facilitate financial crime.
Payment services are provided by Marvli Payment OÜ (company number 16338540), a regulated entity registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (MSB) with registration number M24723823.
PayWayler LTD (hereinafter referred to as “PayWayler”, “we”, “us”, “our”) is a company incorporated under the laws of England and Wales with company number 16563143 and having its registered office at 128 City Road, London, United Kingdom, EC1V 2NX.
Whilst Marvli is the issuer of accounts and provider of payment services, PayWayler acts solely as an agent and partner platform of Marvli.
We have adopted this AML Policy framework to ensure that all necessary measures are implemented to protect the integrity of our services. In this Policy, we pledge to comply with Canadian AML laws, UK regulatory requirements, and internationally recognised anti-money laundering and counter-terrorist financing standards.
2. WHAT IS AML POLICY?
The AML Policy defines the procedures and controls established to prevent the misuse of our services for money laundering, terrorist financing, fraud, or other illicit activities.
KYC processes form an essential part of this policy. Their goal is to ensure that the company accurately identifies and understands its customers, while managing potential risks effectively.
If any unusual or suspicious activity is detected, we take all necessary steps to mitigate associated risks. Where relevant, our staff may request additional information, such as proof of source of funds, business rationale, or other enhanced due diligence documentation.
We maintain organised records of all customer data, including identification documents, verification records, and transaction logs, stored confidentially in accordance with data-protection laws.
Our AML framework includes:
- Identification and verification of customers before establishing a business relationship;
- Risk-based customer due diligence (CDD), including enhanced due diligence (EDD) for high-risk clients;
- Ongoing monitoring of transactions and account activity to detect suspicious patterns;
- Internal and external reporting procedures for suspicious activity to the relevant authorities;
- Continuous AML and compliance training for employees and partners.
During the due diligence process, PayWayler reserves the right to reject customer documents, close accounts, or terminate relationships if suspicious behaviour, falsified information, or non-cooperation is identified.
PayWayler operates in accordance with Marvli Payment OÜ’s AML and KYC program, ensuring that all transactions comply with regulatory standards and international best practices. All client verification and due diligence activities are performed under the supervision of Marvli Payment OÜ.
3. SCOPE OF THE AML POLICY
This Policy covers, but is not limited to, the following key components:
- Customer identification and verification prior to account establishment;
- Risk-based customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk clients;
- Continuous monitoring of transactions and account behaviour to detect inconsistencies;
- Procedures for internal and external reporting of suspicious activities;
- Comprehensive AML and compliance training for employees, agents and partners.
All AML and compliance operations are conducted under the framework of Marvli Payment OÜ’s AML program, and follow its internal policies.
Within the due diligence process, PayWayler LTD reserves the right to decline documents, deny account activation, or terminate a relationship where suspicious activity, falsified information, or non-cooperation is detected.
Marvli Payment OÜ is responsible for reviewing PayWayler clients’ KYC/KYB documentation and ensuring ongoing compliance with applicable AML requirements.
The list of prohibited and restricted countries is available in the Prohibited Countries List (PDF).
For identity verification, sanctions screening and continuous monitoring, PayWayler and Marvli Payment OÜ use the services of Finchecker, a regulated verification and compliance technology provider. Finchecker assists in customer identity verification, global sanctions screening and other due diligence procedures in line with international AML standards and regulatory obligations.
4. RESPONSE TIMES
Requests related to AML matters — including verification, compliance reviews, disputes, or other AML-related inquiries — are typically processed within up to fifteen (15) business days. The same timeframe may apply to account activation or re-verification processes, depending on the complexity of the case and the level of due diligence required.
For any AML-related matters, please contact our Compliance Department via email at [email protected].
(The list of prohibited and restricted countries is available in the Prohibited Countries List (PDF).