i-Account AML Policy

Circle Pay LLC maintains a firm commitment to adequate and appropriate Anti-Money Laundering policies. We take every measure to ensure that all available safeguards are implemented to prevent any violation of the AML and CTF Ordinances, including the following:

• 1. Enhanced KYC measures to manage customers with a higher risk profile, and applying less stringent measures to those representing a lower risk.
• 2. A Compliance Officer (CO) supervising the focal points of all activities.
• 3. A Money Laundering Reporting Officer (MLRO) in charge of reporting conceivably suspicious transactions.
• 4. Continuous training of all relevant staff in order to ensure everybody is fully updated on the AMLO, and appropriate measures to enable frontline staff to discern whether a transaction may be suspicious.
• 5. A risk-management approach to achieve appropriate control and oversight and, accordingly, to determine the appropriate levels of due diligence and monitoring to be applied.
• 6. Safekeeping of all documents obtained in the process of ascertaining the identity of the customer and in connection with the transactions. These shall be kept throughout the business relationship with the customer and for a period of five years after its termination.
• 7. Keep the policies and procedures under regular review for the assessment of the effectiveness of our law-abiding procedures. Circle Pay LLC reserves the right not conduct any business with a party suspected of, or directly involved in, any wrongdoings, like, for instance, money laundering or where funds have been obtained by way of illegal activities.