Anti-Money Laundering & Anti-Terrorist Financing Policies and Procedures
PAYTOO Capital LLC has several policies covering anti-money laundering (“AML”), client due diligence, and terrorist financing. Policies have been implemented to ensure compliance with recent anti-money laundering laws and regulations that meet with Financial Action Task Force (“FATF”) international standards. Regulatory obligations cover the reporting of suspicious transactions, large cash transactions, electronic fund transfers, cross border movements of cash, monetary instruments, client identification, and terrorist financing.
PAYTOO Capital LLC defines money laundering as any act or attempt to disguise the source of money derived from criminal activity. PAYTOO Capital LLC is committed to preventing the use of financial services for money laundering purposes. Only those clients whose activities are reasonably established, are accepted.
PAYTOO Capital LLC has established processes to identify and investigate unusual activities and transactions. All activities and reasonably suspected transactions related to money laundering will be reported to a money laundering officer.
PAYTOO Capital LLC takes reasonable and appropriate measures to establish identities of clients and others for who they may provide financial services to.
PAYTOO Capital LLC records the measures taken to identify clients and retain records of the due diligence for at least five (5) years after the account in question is closed.
PAYTOO Capital LLC takes reasonable steps to help the government fight the funding of terrorism and money laundering activities. Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. We require each borrower to provide to forms of identification to comply with Section 326 of the Patriot Act.
PAYTOO Capital LLC has developed policies and procedures regarding compliance with economic sanctions and anti-terrorism legislation.
PAYTOO Capital LLC performs annual internal reviews of policies and procedures regarding anti-money laundering, anti-terrorism, economic sanctions, and client due diligence to ensure compliance and evaluate continued effectiveness.
Ethical Marketing Practice Policy
PAYTOO Capital LLC does not participate in unethical marketing practices including use of links in connection with Website-Scraping, Spam, Phishing, Phreaking or other illegal practices. Any affiliate identified as advertising in an illegal or unethical manner will immediately be placed under review. Any commissions will be withheld until further investigation is complete. Based on results of such investigation we reserve the right to disqualify such persons from any ongoing participation in the PAYTOO Capital Card affiliate program and from receiving commissions.
This AML was last updated on January 21, 2016.