AML policy

txpaid is committed to preventing money laundering, terrorist financing and sanctions evasion. We apply a risk-based approach in line with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the requirements of our banking and Scheme partners.

We do not establish or maintain business relationships where we cannot meet our due diligence obligations.

This policy applies to all txpaid employees, contractors and directors, and to every merchant relationship and Transaction processed through our Services.

Before onboarding a merchant we verify the identity of the business, its directors and its ultimate beneficial owners holding 25% or more. We confirm the merchant's licences, the nature and intended purpose of the business relationship, the expected transaction volumes and the markets served.

We screen every merchant, director and beneficial owner against sanctions lists, politically exposed person databases and adverse media.

We apply enhanced due diligence to higher-risk relationships, including gambling operators, merchants linked to high-risk jurisdictions and relationships involving politically exposed persons. This may include source of funds and source of wealth checks, additional documentation and senior management approval before onboarding.

We monitor Transactions and merchant activity throughout the relationship to identify unusual patterns, such as activity inconsistent with the merchant's profile, rapid changes in volume, or Transactions from unexpected jurisdictions. We refresh due diligence periodically according to risk, and whenever a material change occurs.

We screen merchants, beneficial owners and Transactions against the UK, EU, UN and US sanctions lists. We do not process Transactions involving sanctioned persons or comprehensively sanctioned jurisdictions.

Staff must report any knowledge or suspicion of money laundering or terrorist financing to the Money Laundering Reporting Officer without delay. The MLRO assesses each report and, where appropriate, submits a Suspicious Activity Report to the National Crime Agency.

Staff must not tell a merchant or any other person that a report has been made or that an investigation is under way.

We keep due diligence records, transaction records and internal and external reports for at least five years after the end of the business relationship or the date of the Transaction, as required by law.

All relevant staff receive anti-money laundering training on joining and at least once a year. Training covers legal obligations, typologies relevant to payments and gambling, red flags and internal reporting procedures.

txpaid has appointed a Money Laundering Reporting Officer who is responsible for overseeing this policy, receiving internal reports, liaising with authorities and reporting to senior management on the effectiveness of our controls. The MLRO can be contacted at management@txpaid.com.