Legal

AML Policy

Last updated: 23 August 2026

VisualPay is committed to effective crime-prevention and detection measures that support law enforcement in fighting financial crime. We maintain firm policies and procedures so that our platform meets legal duties under international anti-money laundering and counter-terrorism financing rules.

Background

Money laundering is any act — or attempt — that makes funds or assets obtained through crime appear to come from a legitimate source. In practice, “dirty” proceeds are converted into “clean” money whose criminal origin is hard to follow. The process is commonly described in three stages:

  • Placement. Introducing criminal proceeds into the financial system.
  • Layering. Moving and reshaping those proceeds through complex transactions to obscure the audit trail, ownership and true source.
  • Integration. Returning laundered value to the economy in a form that looks legitimate.

Laundering begins with proceeds of a predicate offence. Predicate offences include, among others, tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeiting, securities manipulation and copyright infringement. A money-laundering offence may cover property or proceeds derived from illegal activity.

Terrorist financing is knowingly collecting or providing property — including money — directly or indirectly for terrorists. Terrorist activity aims to intimidate the public or to compel government action. Terrorists need funding to operate. Many techniques used in money laundering also appear in terrorist financing, including concealing fund flows and using third parties. Funds are disguised so they seem to come from another source and converted into forms that are harder to trace before use.

1. Main objectives

  • Client identities are verified to a satisfactory standard under VisualPay’s risk-based approach before we do business with them.
  • We know our clients and understand why they use the Service — both at onboarding and throughout the relationship.
  • Staff are trained on their personal legal duties and on VisualPay’s obligations.
  • Staff are trained to spot activity that gives reasonable grounds to suspect money laundering and to report it to the Compliance Officer.
  • Adequate records are retained for the required period.
  • We put in place and keep appropriate procedures to meet these objectives.

2. General principles

Anti-money laundering framework

VisualPay applies policies, procedures and controls intended to stop criminals from using the Service to launder criminal proceeds. Controls are calibrated to the risk associated with each customer.

Customer due diligence (CDD)

VisualPay has CDD procedures to identify users of the Service and, for higher-risk customers, primary beneficial owners and the origin of funds. Procedures include understanding the nature of a customer’s business and watching for unusual transactions.

In general, CDD is designed so that VisualPay can:

  • Identify and verify the applicant for business;
  • Identify and verify the beneficial owner where applicable;
  • Identify and verify cases where the applicant does not act as principal;
  • Obtain information on the purpose and intended nature of the relationship;
  • Conduct ongoing monitoring of the relationship;
  • Establish source of wealth and source of funds;
  • Apply a customer-acceptance policy and confirm applicants meet it;
  • Refuse anonymous accounts or accounts in fictitious names.

Suspicious transactions

Unexplained or anomalous activity that may relate to crime must be reported promptly in writing to the Compliance Officer, who decides whether the matter should be escalated to law enforcement.

Training

All personnel must understand their individual and collective duties and VisualPay’s AML rules. Training helps staff recognise vulnerabilities of the business and report suspicious activity.

Record-keeping

VisualPay keeps records of who was trained and when and how training was delivered. Customer identity records are retained for at least seven years after the business relationship ends. We also keep records of internal suspicion reports made to the Compliance Officer.

3. Our responsibilities

Under international law, money service businesses are generally required to:

  • Maintain a programme covering reporting, record-keeping and customer identification;
  • Follow customer-identification rules and keep specific records for relevant transactions;
  • Report suspicious transactions, large cash transactions and information related to terrorist property.

4. Risk-based approach

Risk is the chance that something may happen, combined with the severity of the resulting harm. In an ML/TF context:

  • At national level: threats and vulnerabilities that undermine the integrity of the financial system.
  • At company level: threats and vulnerabilities that could allow VisualPay to be used for ML/TF.

Clients are treated as low risk by default unless risk factors apply. The presence of any of the following automatic high-risk flags means the client is high risk:

  • Politically exposed person (PEP);
  • A client for whom a suspicious transaction or terrorist-financing report has been filed;
  • A client identified as a terrorist;
  • A client for whom beneficial ownership information cannot be obtained;
  • A client from a high-risk country.

Client, product, service and delivery-channel factors

  • PEPs, heads of international organisations and close associates;
  • Unknown source of funds;
  • Large electronic fund transfer orders to or from high-risk foreign jurisdictions;
  • Third-party involvement without a reasonable explanation;
  • High-risk occupations (for example cash-intensive businesses, offshore activity, business in high-risk countries, online gambling);
  • Unusually complex business structures or transactions;
  • Non-face-to-face identification without a justifiable reason.

Geography

  • Client resides outside the usual or expected client area;
  • Client resides in a known high-crime area;
  • Client has offshore activity or ties to high-risk countries.

Other indicators

  • Volume, timing or complexity of transactions inconsistent with the client’s personal or business profile or with the stated purpose of the account/services;
  • Deposit or transfer values inconsistent with occupation or declared source of funds;
  • Any suspicious-transaction indicators described in the Background section above.

5. Indicators of suspicious activity or higher risk

The examples below may give reasonable grounds to look more closely at a transaction. One factor alone does not automatically mean a report is required, but it does call for deeper review.

General indicators

Suspicion often arises from a combination of factors judged against what is normal and reasonable for the circumstances, for example:

  • Client admits to or makes statements about criminal involvement;
  • Client refuses, dodges or provides misleading, vague or hard-to-verify information;
  • Client produces documentation that appears forged, altered or inaccurate;
  • Client holds accounts at several institutions in one area without a clear reason;
  • Client repeatedly uses an address while frequently changing the name associated with it;
  • Client shows unusual interest in internal controls and systems;
  • Client gives confusing details about a transaction or knows little about its purpose;
  • Client asks questions that suggest an intent to avoid reporting;
  • Client engages in activity unusual for that individual or business;
  • Client appears highly familiar with ML/TF issues;
  • Client refuses to produce personal identification;
  • Client frequently travels to a high-risk country.

Industry-specific examples

  • Requesting a foreign-exchange rate above the posted rate;
  • Offering to pay fees above posted fees;
  • Exchanging currency and asking for the largest possible denomination notes in a foreign currency;
  • Knowing little about the payee’s address or contact details, being reluctant to disclose them, or requesting a bearer instrument;
  • Wanting a cheque in the same currency to replace one being cashed;
  • Wanting cash converted to a cheque where cheque issuance is not a normal service;
  • Exchanging cash for numerous small postal money orders for many other parties;
  • Transacting with counterparties in locations unusual for the client;
  • Instructing that funds be collected by a third party on behalf of the payee;
  • Large purchases of traveller’s cheques inconsistent with known travel plans;
  • Purchasing money orders in large volumes.

6. Data requests

To reduce ML/TF risk, VisualPay does not accept or send payments to unidentified third parties. Each customer may only send and receive payments through their own accounts — including electronic payment accounts, bank accounts and credit or debit cards.

Under our Know Your Customer (KYC) approach, authorised staff may verify a customer. When verification is required, the customer may need to provide:

  • Information about the services for which funds were received;
  • A screenshot confirming receipt and withdrawal of funds;
  • Any further information reasonably requested.

We reserve the right to refuse to process a transaction at any stage if we suspect money laundering or other criminal activity.

7. Restricted activities and clients

To control ML risk, VisualPay does not provide services and will refuse account opening for clients whose risk is unacceptable, including the categories below.

Private individuals

  • Negative information from trusted sources (for example World-Check or public authority websites) indicating a possible link to criminal proceeds, laundering or terrorism;
  • Funds previously frozen or seized in connection with suspected crime;
  • Reinsurance services where the provider is not properly licensed and lacks adequate supervision;
  • Attempts to avoid providing information or to conceal economic activity;
  • Trafficking in arms and ammunition;
  • Economic activity that must be registered in legal-entity form;
  • Unlicensed foreign-exchange intermediaries (such as forex dealers or binary options) and other unlicensed investment services;
  • Transactions or payments that are complex, unusually large relative to the customer’s activity, or unclear in legal and economic purpose;
  • Escort organisation or related erotic / pornographic content distribution;
  • Cash collection services;
  • Debt recovery providers;
  • Distribution of drugs, vitamins and nutritional supplements;
  • Detective services;
  • Direct marketing providers;
  • Pyramid schemes;
  • Telemarketing;
  • Pawnshop services;
  • Auctions and related services;
  • Tobacco and alcohol product distribution.

Legal persons

  • Attempts to avoid providing information or to conceal economic activity;
  • Negative information from trusted sources indicating a possible link to criminal proceeds, laundering or terrorism;
  • Funds previously frozen or seized in connection with suspected crime;
  • Reinsurance services where the provider is not properly licensed and lacks adequate supervision;
  • Trafficking in arms and ammunition;
  • Investment or ancillary investment services where the provider is not properly licensed in the EEA or in another country with AML/CFT standards equivalent to EU law;
  • Entities recognised as shell companies;
  • Unlicensed gambling organisation;
  • Unclear reason for establishing the legal entity, or vague information about economic objectives;
  • Unlicensed foreign-exchange intermediaries (such as forex dealers or binary options);
  • Transactions or payments that are complex, unusually large relative to the customer’s activity, or unclear in legal and economic purpose;
  • Escort organisation or related erotic / pornographic content distribution;
  • Cash collection services;
  • Debt recovery providers;
  • Distribution of drugs, vitamins and nutritional supplements;
  • Detective services;
  • Direct marketing providers;
  • Pyramid schemes;
  • Telemarketing;
  • Pawnshop services;
  • Auctions and related services;
  • Tobacco and alcohol product distribution.

Under VisualPay’s internal AML/CFT procedure, customers fall into two risk categories: low risk and high risk. Enhanced due diligence (EDD) is required for high-risk customers.

A high-risk client includes someone who:

  • Is a politically exposed person, a family member of a PEP, or a close associate; or
  • Has financial claims and related obligations exceeding CAD 10,000.

8. Sanctions

VisualPay must not transact with individuals, companies or countries on applicable sanctions lists. We screen against relevant lists in the jurisdictions where we operate.

VisualPay has no appetite to establish or maintain a customer or counterparty relationship with any natural person or legal entity designated on the lists below, or where otherwise prohibited by law or regulation:

  • Sanctions lists administered by the United States Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons list;
  • The United Nations Security Council Sanctions List (UN);
  • The Consolidated List of European Union Financial Sanctions (EU);
  • Any other applicable sanctions list.

We also pay particular attention to entities from jurisdictions on the FATF list of non-cooperative countries and territories, and to monetary operations or transactions performed by or on behalf of them.

9. Non-serviced countries

VisualPay does not open accounts or provide services to clients from the following countries:

  • Islamic Republic of Afghanistan (AF)
  • Republic of Angola (AO)
  • Belarus (BY)
  • Bosnia and Herzegovina (BA)
  • Republic of Botswana (BW)
  • Commonwealth of The Bahamas (BS)
  • Kingdom of Cambodia (KH)
  • Republic of Burundi (BI)
  • Democratic Republic of the Congo (CD)
  • Central African Republic (CF)
  • Republic of the Congo (CG)
  • People’s Democratic Republic of Algeria (DZ)
  • Republic of Ecuador (EC)
  • State of Eritrea (ER)
  • Federal Democratic Republic of Ethiopia (ET)
  • Republic of Ghana (GH)
  • Republic of Guinea (GN)
  • Republic of Guinea-Bissau (GW)
  • Co-operative Republic of Guyana (GY)
  • Republic of Haiti (HT)
  • Republic of Iraq (IQ)
  • Islamic Republic of Iran (IR)
  • Japan (JP)
  • Republic of Kenya (KE)
  • Democratic People’s Republic of Korea (KP)
  • Lebanese Republic (LB)
  • Republic of Liberia (LR)
  • Libya (LY)
  • Republic of the Union of Myanmar (MM)
  • Federal Republic of Nigeria (NG)
  • Islamic Republic of Pakistan (PK)
  • Republic of Serbia (RS)
  • Russian Federation (RU)
  • Republic of the Sudan (SD)
  • Democratic Socialist Republic of Sri Lanka (LK)
  • Federal Republic of Somalia (SO)
  • Republic of South Sudan (SS)
  • Syrian Arab Republic (SY)
  • Republic of Tunisia (TN)
  • Republic of Trinidad and Tobago (TT)
  • Ukraine (UA)
  • Republic of Uganda (UG)
  • United States of America (US)
  • Republic of Vanuatu (VU)
  • Bolivarian Republic of Venezuela (VE)
  • Republic of Yemen (YE)
  • Republic of Zimbabwe (ZW)

10. Monitoring for suspicious activity

VisualPay’s AML programme includes due diligence on customers and beneficial owners, ongoing monitoring and reporting. From time to time we may request information about transactions on a customer’s VisualPay account and about the parties to those payments. If the customer does not respond adequately or in time, we may reject the relevant payments, subject to applicable AML laws and regulations.

11. Changes

We may update this AML Policy at any time. The “Last updated” date on this page is the effective date. Continued use of the Service after a change is acceptance of the revised Policy.

12. Contact

Questions about this Policy: Contact Us or [email protected].