AML/CTF Policy

Due to the fact that virtual currency is often exploited for money laundering (ML) and terrorist financing (TF), one of the biggest challenges for virtual currency service providers is to ensure and maintain specific measures in order to prevent illicit activity within the company. Therefore, Match2Pay establishes and implements its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy in accordance with the local Law, related legal regulations, recommendations, guidelines and best practices in the field. The Policy on Prevention of Money Laundering and/or Terrorist Financing (the AML Policy) of Match2Pay UAB (Match2Pay or the Company) establishes rules that must be adhered to by the Company in order to properly manage risks of ML and/or TF as well as ensure reliable and secure services with high standards of integrity and transparency.

The AML Policy is based on the following legal acts:

• The Law on Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania (No VIII-275, as of 19 June 1997 with all its later amendments and updates); 
• The Law on Implementation of economic and other financial sanctions of the Republic of Lithuania (No IX-2160, as of 22 April 2004 with all its later amendments and updates); 
• Procedure on Suspension of Suspected Money Operations or Transactions and Submission of Information regarding Suspicious Money Operations or Transactions to the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania approved by Order No 1V-701 of the Minister on the Interior of the Republic of Lithuania as of 16 October 2017 (with all its later amendments and updates); 
• Guidelines for Managers of Digital Wallets and Operators of Cryptocurrency Exchange to Prevent Money Laundering and/or Terrorist Financing approved by Order of the Director of the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania as of 10 January 2021 (with all its later amendments and updates);
• FATF recommendations;
• Other legal acts that are not indicated in the above list.

Key elements of the AML Policy

Customer Due Diligence (CDD). CDD refers to the minimum due diligence measures which must be performed at the start of each business relationship. The establishment of the Client’s identity and of the beneficiary is the process of collection and verification of the Client’s information. Know Your Client (KYC) is an obligatory due diligence process in the Company performed in order to identify its Clients and ascertain relevant information pertinent to doing financial business with them. The main purpose of the KYC process is to prevent identity theft, fraud, ML or TF. The initial step of the KYC process is to collect and document identification data about the Client and the Client’s beneficiary. Additionally, Match2Pay verifies the obtained information against reliable and independent sources. Customer due diligence information allows assessing the extent to which the Client poses certain risks. Information, documents and data provided to Match2Pay during the identity verification of the Client are processed in accordance with the Company’s Privacy Policy.

Risk Assessment. While assessing the risks, Match2Pay applies the risk-based approach. A risk-based approach means that the Company has an understanding of the ML and TF risks to which it is exposed and applies prevention measures in a manner and to an extent that would guarantee the mitigation of such risks. This allows Match2Pay to focus its resources and adopt enhanced measures in higher-risk scenarios.

Ongoing due diligence (ODD). ODD refers to periodic review of Clients’ activity, updating the Clients’ profile and comparing new information to the previously obtained data.

Transaction monitoring. Match2Pay is conducting continuous monitoring of the Clients’ transactions in order to ensure that the executed transactions correspond to the Company’s knowledge of the Clients (nature of transactions, nature of risk and knowledge about the source of funds, etc.). Ongoing monitoring is performed on all business relationships regardless of the Clients’ risk rating calculated under the risk-based approach.

Objectives of transaction monitoring are the following: 

• To identify suspicious transactions; 
• To ensure the relevance of the Client and beneficiary data, the purpose and nature of the business relationship; 
• To ensure the relevance of the Client’s risk in the event of a change in circumstances;
• To determine whether the Client’s transactions correspond to the information previously collected on the Client; and 
• To properly understand the Client’s activities and to create an exhaustive Client profile. 

Communication with Competent Authorities. Match2Pay is obligated notify the appropriate authorities and assist with any subsequent actions if there is any reason to believe that any property, regardless of value, is derived either directly or indirectly from criminal activity or participation in such activity, or that its intended use is to support one or more terrorists or terrorist organizations.

Record Keeping. Match2Pay maintains appropriate records in relation to every Client according to the Law on Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania. In order to enable efficient investigation, prosecution, and confiscation of criminal property, record keeping is crucial part of the AML program within the company.