Introduction UAB

“Globopay” Anti-Money Laundering and “Know Your Customer” policy (hereinafter — “AML / KYC Policy”) is designed to prevent and reduce possible risks of involvement of the https://wallet.globopay.eu platform in any types of illegal activities. Both international and local regulations require UAB “Globopay” to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery, as well as to take action in case of any suspicious activity on the part their users.

Verification procedures

Customer due diligence is one of the international standards for preventing illegal activity. ID confirmation UAB “Globopay” is an identity verification procedure that requires the User to provide reliable, independent source documents, data or information (e.g. national ID, passport, bank statement, utility bill). For such purposes, UAB “Globopay” works with an organization certified for these purposes. UAB “Globopay” reserves the right to verify the identity of the User on an ongoing basis, especially if his identification information has been changed or their actions seem suspicious (unusual for a particular User). In addition, UAB “Globopay” reserves the right to request up-to-date documents from users, even if they have passed identity verification in the past. User identification information will be collected, stored, transmitted and protected strictly in accordance with the Privacy Policy and relevant provisions.

Verification of sanctions and lists of politically exposed persons.

UAB “Globopay” instructs a certified company to verify Users against a list of recognized sanctions and politically exposed persons. At the adaptation stage, when the user submits an application. Each Anti-Fraud and AML Alert manually by a Compliance Officer monthly by automatically launching with a script to re-check the entire client database.

Compliance Officer

The Compliance Officer is a person duly authorized by UAB “Globopay” who is responsible for ensuring that the AML / KYC Policy is effectively implemented and adhered to. The Compliance Officer is responsible for overseeing all aspects of AML / CFT activities, including but not limited to: - Collection of user identification information; - Establish and update internal policies and procedures for completing, reviewing, submitting and maintaining all reports and records required by applicable laws and regulations; - Monitoring transactions and investigating any significant deviations from normal activities; - Implementation of a records management system for the proper storage and retrieval of documents, files, forms and logs; - Regular update of the risk assessment; - Providing information to law enforcement agencies in accordance with applicable laws and regulations; - The Compliance Officer has the right to interact with law enforcement agencies that are involved in the prevention of money laundering, terrorist financing and other illegal activities.

Monitoring transactions.

With regard to the AML / KYC policy, UAB “Globopay” will monitor all transactions and reserves the right to: ensure that transactions of a suspicious nature are reported to the appropriate law enforcement authorities through the Compliance Officer; request additional information and documents from the User in case of suspicious transactions; suspend or terminate the User's Account if there are reasonable suspicions that such User is engaged in illegal activity. The above list is not exhaustive and the Compliance Officer will monitor user transactions on a daily basis to determine whether such transactions should be reported and viewed as suspicious or considered bona fide.

Risk assessment

UAB “Globopay”, in accordance with international requirements, takes a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, UAB “Globopay” can ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified. This will allow resources to be allocated in the most efficient way. The principle is that resources should be prioritized so that the greatest attention is paid to the greatest risks.