AML & KYC Policy
PRIVATEPAY LIMITED
In line with the safety of our users and the legal requirements of the United States of America, Canada, the European Union, and other applicable jurisdictions, PRIVATEPAY LIMITED, in cooperation with its regulated Banking and Payments-as-a-Service (BaaS) provider Piggy Pay Inc., has implemented and adopted KYC (Know Your Customer) and AML/CTF (Anti-Money Laundering and Counter-Terrorism Financing) policies, in compliance with the requirements of FinCEN and FINTRAC.
Purpose of These Policies
The purpose of these policies is to effectively combat money laundering and terrorist financing (AML/CTF). Through proper identification of users and close monitoring of transactions performed by Piggy Pay Inc., we aim to identify and prevent unlawful activities.
User Identification
PRIVATEPAY LIMITED is obliged to identify, beyond a reasonable doubt, the identity of persons enabled to perform transactions on the platform. Identity documents are collected and verified using specialized software.
To prevent misuse, a selfie or short video recording together with an identity document is required. Verification may be automated or manually reviewed by authorized compliance personnel.
Know Your Customer (KYC) Questionnaire
Why Do We Ask for Personal Information?
PRIVATEPAY LIMITED applies the KYC principle to prevent fraud, identity theft, and other unlawful activities. This process applies to all clients and does not imply suspicion.
Sources of Funds
Clients must indicate their sources of funds (e.g. salary, freelance, business income, etc.). Additional details may be required for compliance assessment.
Planned Monthly Turnover
Clients must indicate their expected monthly transaction volume to determine appropriate monitoring and risk assessment.
Political Exposure
Clients must disclose involvement in political activities and whether close associates hold politically exposed positions (PEP requirements).
Ultimate Beneficiary
The ultimate beneficiary is the account holder and owner of the funds. Accounts are for personal use only.
Frequency of Data Collection
- During registration
- About once a year for updates
- In case of unusual or large transactions
Failure to Provide Data
Failure to provide required information may result in restriction of services until compliance is satisfied.
Data Access
PRIVATEPAY LIMITED and Piggy Pay Inc. store personal data securely and use it solely for compliance and regulatory purposes. Information may be shared with authorities as required by law.
User Identification — Companies
For legal entities, AML/KYC procedures are stricter and include verification of ownership structure, directors, shareholders, registered address, and beneficial owners.
- Certificate of Incorporation
- Founding documents
- Identification of directors and representatives
- Shareholder agreements
- Proof of registered address
- Financial statements or bank references
Transactions Monitoring
All transactions are monitored using proprietary software and reviewed by AML specialists for suspicious activity.
Additional Verification
Enhanced due diligence may be required for high-risk activity, increased transaction volumes, or suspicious behavior.
Basic AML/CTF Rules
- KYC applies to all clients
- No cash deposits or withdrawals
- No exceptions for compliance documentation
- Accounts and transactions may be restricted or terminated
- Clients are not informed of suspicious activity reports
Sanctioned Countries
PRIVATEPAY LIMITED does not provide services to individuals located in sanctioned or high-risk jurisdictions in accordance with OFAC, EU, UN, UK, Canada, FATF, and other authorities.
Tiers of KYC Verification
A three-tier verification system is applied. Higher transaction volumes require enhanced due diligence and additional verification procedures.
Last updated: 04 May 2026