AML/KYC Policy
ANTI – MONEY LAUNDERING AND KNOW YOUR CUSTOMER POLICY
Rariti, Inc., a C-Corporation registered in Delaware, USA, operates the Payezy platform, which facilitates cross-border money transfers between the USA and India. This policy outlines our approach to Anti-Money Laundering (AML) and Know Your Customer (KYC) measures to ensure compliance with relevant regulations, including the USA PATRIOT Act, Bank Secrecy Act (BSA), and Office of Foreign Assets Control (OFAC) regulations.
Our commitment is to prevent and detect money laundering, terrorist financing, and other illicit financial activities while protecting our customers' data.
1. Customer Identification Policy (KYC)
1.1 Customer Acquisition
We acquire customers through our website, www.payezy.io, where users register to use our money transfer services. During registration, customers are required to provide personal identification details, including but not limited to:
Full legal name
Date of birth
Residential address
Government-issued identification (passport, driver’s license, etc.)
Contact information (email, phone number)
All personal information collected will be verified using industry-standard methods to ensure the authenticity of the customer's identity.
1.2 Sanctions/PEP/Adverse Media Screening
We implement stringent screening of customers against the following:
Sanctions lists, including the OFAC list, UN sanctions, and EU/UK sanctions lists
Politically Exposed Persons (PEPs)
Adverse media sources, focusing on individuals or entities involved in criminal activities, money laundering, or terrorism
Automated tools will be used to cross-reference customers against these databases to ensure compliance. Any matches will be flagged for further review by our compliance team.
1.3 Policy on OFAC Sanctioned Countries
Rariti, Inc. adheres to all OFAC sanctions and blocks any transactions involving countries or individuals on OFAC's Specially Designated Nationals (SDN) list. We do not onboard or allow transactions involving customers from OFAC-sanctioned countries, including but not limited to North Korea, Iran, and Syria.
Our system automatically blocks accounts and transactions linked to these regions to ensure full compliance with sanctions regulations.
2. Monitoring and Reporting of Unusual Activities
Rariti, Inc. maintains active monitoring of customer transactions to detect and report suspicious activities that could be indicative of money laundering or fraud. This includes:
Monitoring transaction patterns for irregularities
Identifying unusual behaviors such as high-volume transfers, transfers involving high-risk jurisdictions, or rapidly repeated transactions
All flagged activities are reported to relevant authorities, including the Financial Crimes Enforcement Network (FinCEN), and information is shared with our vendors, including Cybrid Inc., where necessary. In cases of suspected fraudulent or suspicious behavior, the customer account may be frozen pending further investigation.
3. Collaboration with Cybrid Inc.
We actively collaborate with Cybrid Inc. for compliance in monitoring and sharing information on any unusual customer behavior. In the event of potential fraud, suspicious activities, or any indications of money laundering, we will immediately communicate with Cybrid Inc. and provide them with the necessary information to assist in their review and actions. All such exchanges are carried out in a secure and lawful manner.
4. Customer Data Protection
4.1 Data Security
Rariti, Inc. is committed to safeguarding customer data. We comply with data protection regulations such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) to ensure the privacy and security of all personal information collected.
We employ advanced encryption, multi-factor authentication, and secure data storage practices to protect sensitive customer data from unauthorized access, theft, or breaches.
4.2 Sharing of Information
Customer data is only shared with regulatory bodies, law enforcement, or our vetted partners (e.g., Cybrid Inc.) as necessary for compliance with AML/KYC regulations. We do not share customer data with any third parties for commercial or marketing purposes.
5. Training and Awareness
All employees of Rariti, Inc. undergo regular training on AML/KYC regulations, data protection laws, and how to identify and report suspicious activities. We ensure that our team is well-versed in regulatory changes and industry best practices.
6. Compliance and Review
Rariti, Inc. conducts regular audits and reviews of its AML/KYC policies and procedures to ensure they remain compliant with evolving regulations. We also review our partnership with Cybrid Inc. and other service providers to ensure that they continue to meet our compliance standards.
7. Policy Statement on OFAC and Sanctioned Countries
We fully comply with all OFAC sanctions and will not conduct business with or on behalf of individuals, companies, or governments located in OFAC-sanctioned countries. We will block access to our platform for any customer attempting to access services from these countries.
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