Anti-Money Laundering Policy

1. General provisions

1.1. This Anti-Money Laundering (AML) Policy outlines the measures and procedures for detecting, preventing, and reporting activities related to Money Laundering (ML) and Terrorist Financing (TF). These measures ensure compliance with applicable laws, such as the Money Laundering Prevention Act and relevant international standards.
1.2. All directors, employees, contractors, and agents of AynaPay.com (collectively referred to as “Representatives”) are required to adhere to this policy. Representatives must acknowledge their understanding of this policy in writing.
1.3. This policy aligns with the legal and regulatory requirements, including international standards such as the FATF Recommendations and relevant local laws

2.1. Money Laundering (ML): Any process involving proceeds of crime to conceal their origin or facilitate illegal activities
2.2. Terrorist Financing (TF): Providing or collecting funds with the intention or knowledge that they will be used for terrorism-related activities.
2.3. Client: Any natural or legal person using AynaPay.com's services.
2.4. Transaction: Any transfer of funds, payments, or cryptocurrency involving AynaPay.com services.
2.5. Beneficial Owner: A person who directly or indirectly owns or controls at least 25% of a legal entity or exercises significant influence over it.
2.6. Politically Exposed Person (PEP): An individual entrusted with prominent public functions, including their family members and close associates.
2.7. Compliance Officer (CO): A designated individual responsible for implementing and monitoring adherence to this AML Policy
2.8. International Sanctions: Non-military measures imposed by authorities to achieve foreign policy objectives.

3.1. Compliance Officer (CO):
- Responsible for the effectiveness of the AML policy.
- Monitors compliance, conducts training, and acts as the liaison with regulatory authorities.
- Prepares an annual compliance report for AynaPay.com’s Board of Directors.
3.2. Risk-Based Approach (RBA): AynaPay.com applies a risk-based approach to mitigate ML/TF risks, considering client profiles, transaction patterns, and geographic exposure.

4.1. Client Identification:
- Verify the identity of clients and their representatives using government-issued identification documents or digital means.
- Obtain and verify information about the beneficial owner(s).
4.2. Enhanced Due Diligence (EDD):Applied to high-risk clients, including PEPs, clients from high-risk jurisdictions, and unusual or complex transactions. Measures include:
- Verifying the source of funds.
- Conducting regular transaction monitoring.
- Seeking senior management approval for establishing relationships.
4.3. Ongoing Monitoring:
- Regularly update client information.
- Monitor transactions to ensure consistency with the client’s known activities.

5.1. Suspicious Transaction Reporting (STR):
- Any unusual or suspicious activity must be reported to the CO.
- The CO is responsible for notifying the Financial Intelligence Unit (FIU) as per legal requirements.
5.2. Prohibited Transactions:AynaPay.com will not process transactions involving:
- Clients or funds under international sanctions.
- Transactions without clear economic or legal justification.

6.1. AynaPay.com retains client and transaction records for at least five years after the termination of the business relationship or completion of a transaction.
6.2. Records include:
- Client identification documents.
- Transaction details.
- Correspondence and risk assessments.

7.1. Regular training is provided to all Representatives to ensure understanding of AML regulations and emerging risks.
7.2. Training materials and attendance records are retained for three years.

8.1. Annual reviews of this policy and its implementation are conducted by the CO.
8.2. Inspection results are documented and shared with senior management, along with recommendations for addressing deficiencies.

9.1. AynaPay.com complies with all applicable international sanctions.
9.2. The CO monitors and updates the sanctions list, ensuring that no services are provided to prohibited entities or individuals.

10.1. AynaPay.com employs robust technology to safeguard client data and transactions, including:
- End-to-end encryption.
- Two-factor authentication.
- Continuous monitoring for suspicious activities.
10.2. A modular system design isolates sensitive operations, minimizing the risk of system-wide vulnerabilities.

11.1. Ensures adherence to the AML Policy.
11.2. Maintains records of suspicious activities.
11.3. Reports regularly to the Board of Directors and regulatory authorities.