As a Financial Institution, FMPay (the Company) has a regulatory and moral obligation to put measures in place to manage and mitigate the Financial Crime Risk. The Company recognises that its position as a Financial Institution and the nature of its products expose it to the risk that it may be used for purposes relating to financial crime and money laundering. These include:
Money laundering;
Terrorist financing;
Tax evasion;
Avoiding sanctions;
Fraud;
Anti-bribery and corruption;
Market abuse.
FMPay is committed to high standards of anti-money laundering, counter terrorist financing, counter proliferation financing and sanctions implementation. FMPay’s aim is to remain compliant with all legalisations. We do so by establishing, implementing, maintaining, and reviewing adequate, up to date and correct policies and procedures sufficient to ensure the Company maintains regulatory compliance, resilience and counter the risks the firm might be used as a conduit for financial crime. The Company is exposed to high legal, financial and reputational risk, if it does not meet the requirements of “know your customer” principle, ongoing CDD, financial sanctions and maintains business relationship with the persons involved in criminal dealings and contacts related to terrorist activities.
To minimise the risk that FM Finance Ltd. is used to further Financial Crime;
To ensure that products and services operate in such a way that money laundering risk and other risks relating to proceeds of crime are mitigated.
FMPay actively undertakes steps to understand who our customer is. Know Your Customer (“KYC”) is the process of formally identifying our customers throughout various stages of the business relationship in order to manage financial crime risks.
Verification and continuous assessment of KYC information about customers´ and their beneficial owners (Bos) is an essential method in Anti-Financial Crime activity of the Company.
It is very important to know the customer’s business or personal activities, as well as the origin of the customer’s income and assets. This is a legal and practical responsibility that allows us to protect our Business, the integrity of the Financial Industry and ultimately our customers.
The Company verifies and assesses the customer’s business or personal activities observing the following principles:
Obtain information from the customer prior to beginning of cooperation, and throughout the relationship lifecycle;
The Company gets to know its customers’ business or personal activities:
In all cases, the Company must identify the beneficial owner and controllers of our customers. The Company starts the process of identifying the customer’s BO by requiring the customer to fill in the customer's questionnaire. FMPay uses multiple methods to verify and authenticate the information that is provided on the questionnaire.
A person will not be accepted as a customer if the identification process proves to be incomplete and invalid.
For Natural Persons, at a minimum, we will request:
Completed questionnaire;
Copy of identification document (ID card or Passport);
Copy of Utility Bill or other proof of address;
Additional documents requested by the Company.
Where the natural person is a Politically Exposed Person(PEP) or a Relative and Close Associate (RCA) we will require additional information in keeping with the risk exposure of the PEP/RCA.
For Legal Persons, at a minimum, we will request:
Fulfilled questionnaire;
Registration certificate;
Articles of association or partnership agreement;
Document about the owners;
Document about the election/appointment of the management body (management board/CEO);
Document proving the right of representation;
Certificate of Good Standing if applicable;
Additional documents requested by the Company.
At a minimum, customers are only accepted once:
They are fully identified in accordance with the Company’s procedures;
They can prove source of income and/or source of wealth;
They do not engage in prohibited activities;
They are not a sanctioned person or operate in sanctioned or FATF black-listed countries;
Their website is compliant with card scheme rules.
KYC is an ongoing exercise and FMPay will not accept customers or discontinue relations with persons or entities not meeting the above acceptance criteria at any time during the relationship.
Money laundering is the processing of illegally obtained gains to disguise their illegal origin so that they appear to be legitimate.
Our Anti-Money Laundering objective is achieved by establishing and implementing appropriate processes, systems and controls to protect FMPAY, its customers, shareholders, employees, and the financial industry. The AML Policy is informed by applicable laws, regulations, regulatory guidance and best practice from the United Kingdom, and internationally.
Our Anti-Money Laundering controls include:
The appointment of a Compliance Officer and a Money Laundering Reporting Officer (“MLRO”);
Implementing policies and procedures, and having clear allocation of responsibilities;
KYC principles and ongoing Customer Due Diligence (“CDD”) requirements, incorporating Customer Identification and Verification processes;
Conducting enhanced due diligence (“EDD”) on customers assessed as higher risk; such as PEPs and RCAs;
Transaction monitoring and screening to identifying suspicious or unusual activity;
Risk assessments and risk assignments;
Prohibition and restriction of some activities;
Suspicious transaction reporting process;
Mandated AML training;
Independent testing including internal and external audits.
FMPay recognises that Money Laundering is a present and evolving threat. The company prohibits the use of its resources, services and products by employees, customers and other stakeholders to participate in or facilitate money laundering activities.
FMPAY is subject to the UK Bribery Act 2010 as well as other extra-territorial laws including the US Foreign Corrupt Practices Act.
The Company has a zero-tolerance approach to Fraud, Bribery and Corruption and considers such activity to be illegal, immoral and unethical. FMPAY, its Staff and associated persons are prohibited from engaging in Fraud, Bribery and Corruption.
Our Fraud, Bribery and Corruption controls include:
The appointment of a Compliance Officer and a Money Laundering Reporting Officer (“MLRO”);
Implementing policies and procedures, with minimum standards to be complied with and having clear allocation of responsibilities;
Customer Due Diligence, Employee Due diligence and Third Party Due Diligence;
Limitations on interactions with third parties;
Mandatory training;
Whistleblowing procedures;
Conflict of interest declarations;
Acceptable gifts, hospitality and entertainment guidance and a gifts and hospitality reporting;
Independent testing and internal audits.
FMPay employees must ensure their interactions or relationships do not induce, or can be seen to induce, improper action to obtain or retain a business or personal advantage.
Third parties, including contractors and vendors must not induce, or can be seen to induce, improper action to obtain or retain a business or personal advantage.
Customers must not use FMPAY products and services to facilitate fraud, pay or receive of bribes or funds from corrupt activity.
FMPAY is committed to combatting the financing of terrorism and the proliferation of weapons of mass destruction. We comply with all applicable laws and regulations in the jurisdictions in which we operate.
Terrorist financing is the direct or indirect use of funds for terrorist acts. The scope of terrorism financing includes direct and indirect actions to make available, accumulate, provide or lend funds to terrorists or for terrorist acts, including the proceeds of crime or legally obtained wealth.
Proliferation financing refers to the act of providing funds or financial services which are used, in whole or in part, towards the use of nuclear, chemical or biological weapons and their means of delivery and related materials, in contravention of national laws and international obligations.
Our Anti-Terrorist and Anti-Proliferation controls include;
The appointment of a Compliance Officer and a Money Laundering Reporting Officer (“MLRO”);
Implementing policies and procedures, and having clear allocation of responsibilities;
Ongoing Customer Due Diligence;
Prohibited countries and geographic regions;
Transaction monitoring and screening to identifying suspicious or unusual activity;
Risk assessments and risk assignments;
Prohibition and restriction of some activities;
Suspicious transaction reporting process;
Mandatory training;
Independent testing including internal and external audits.
Sanctions are restrictions on activity with targeted countries, governments, entities, individuals and industries that are imposed by bodies or governments such as the United Nations, the United Kingdom, the United States, the European Union, and other individual countries or groups of countries.
As a financial institution we comply with the legal and regulatory obligations in the jurisdictions where we operate, and also where we facilitate payments to and from. FMPay’s sanctions compliance policy and procedures are designed to ensure that the Company and its employees know how to identify and manage the legal, regulatory, and reputational risks associated with sanctions.
Our Sanctions controls include:
The appointment of a Compliance Officer and a Money Laundering Reporting Officer (“MLRO”);
Implementing policies and procedures, and having clear allocation of responsibilities;
Ongoing Customer Due Diligence;
Prohibited countries and geographic regions;
Transaction monitoring and screening;
Risk assessments;
Employee training;
Independent testing including internal and external audits.
All stakeholders are encouraged to report their concerns where they have identified breaches or potential breaches by the Company, its Representatives or Employees, the companies we do business with, or Customers of FMPay.
If you’d like to file an official report, then please send us email on compliance@fmpay.me
As an alternative you can write to us by post:
The Compliance Officer
FM Finance Ltd (dba FMPay)
Suites 15-16 Pure Offices
Hatherley Lane, Cheltenham Office Park
GL51 6SH Cheltenham
United Kingdom
All information received is confidential. We aim to confirm receipt of your concern within 24 hours of receiving your communication. In our response we will explain to you how your concern has been handled and what the next steps are.
The Company complies with the General Data Protection Regulation (GDPR) and UK Data protection Act.
The Company will conduct regular evaluations to ensure adequate oversight to mitigate data protection related risks posed to the company and our clients.
More details about FMPay’s approach to data protection are found here https://fmpay.me/resources/privacy-policy.
