Anti-Money Laundering Statement

At Clarico Pay Ltd, we are dedicated to maintaining the highest standards of compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. As a Financial Conduct Authority (FCA) registered Small Payment Institution (SPI), we adhere to all relevant UK regulations, including the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017.

Our Commitment:

• We are committed to preventing our platform from being used for money laundering or terrorist financing. We employ stringent procedures to identify and mitigate risks, ensuring that all transactions conducted through our services are secure and legitimate.
• We perform thorough customer due diligence on all users, including identity verification and ongoing transaction monitoring. Enhanced due diligence is applied to higher-risk customers, ensuring compliance with AML regulations.
• Our automated systems continuously monitor transactions for unusual patterns or behaviours that may indicate suspicious activity. Any transactions that appear to deviate from a customer’s normal behaviour are flagged for further investigation by our compliance team.
• Our team is trained to identify and report any suspicious activities to the appropriate authorities, including filing Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) when necessary.
• We do not allow Politically Exposed Persons (PEPs) or individuals with known close associations to PEPs to use our services. Any user identified as a PEP will be promptly reviewed and the account may be terminated in accordance with our policies.

• We require all users to provide accurate information during account registration and to comply with our AML and CTF policies. Failure to provide necessary information or attempts to use our platform for illegal purposes will result in account suspension or termination and may be reported to regulatory authorities.

Sanctions Compliance & Asset Freezing

We maintain a zero-tolerance policy toward sanctioned jurisdictions, entities, and individuals:

• Comprehensive Screening: All customers, beneficial owners, and transfer counterparties are screened at onboarding and in real-time against the UK Sanctions List, as well as UN, EU, US (OFAC) and FATF lists. This is not an exhaustive list. The company also complies with other applicable regional and international sanctions lists.
• Real-Time Prevention: Our automated systems intercept and screen every payment instruction before funds are moved. Any transfer involving a Designated Person or a sanctioned entity is automatically blocked.
• Ownership and Control: We apply “Targeted Financial Sanctions” not only to listed individuals but also to entities owned or controlled by them, in accordance with the Sanctions and Anti-Money Laundering Act 2018.
• Statutory Reporting: In the event of a sanctions match, we will immediately freeze the relevant assets and fulfill our legal obligation to report the match to the Office of Financial Sanctions Implementation (OFSI) and the FCA within the required timeframes.
• Fuzzy Matching: We utilize advanced matching logic to identify aliases, transliteration variations, and attempts to circumvent screening through minor spelling changes.

Our Approach:

• We adopt a risk-based approach to AML compliance, applying appropriate levels of scrutiny and due diligence based on the risk profile of each customer and transaction.
• Our staff receive regular training on AML and CTF regulations and procedures to ensure they are equipped to identify and address potential risks. We continuously update our policies and procedures to stay aligned with the latest regulatory requirements and industry best practices.

Protecting Our Platform and Users:

Your trust and security are our top priorities. We aim to provide a safe and compliant platform for all users. We are committed to transparency, regulatory compliance, and maintaining the integrity of our services.

If you have any questions about our AML policy or how it affects you, please contact our customer support team for more information.