Anti-Money Laundering

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Overview

• As a global financial services provider, digiID PAY is committed to compliance with all applicable laws and regulations regarding Anti-Money Laundering ("AML").
• digiID PAY’s policy and practice is to try to prevent people engaged in money laundering, fraud, and other financial crimes, including terrorist financing, from using digiID PAY’s services.
• The ever-present threat of criminal activity has forced governments and regulators to increase their focus on AML/Counter-Terrorist Financing (CTF) issues. digiID PAY’s philosophy is to develop and utilize new methods of identification and authentication that go beyond the traditional KYC collection of static data elements. Industry should leverage existing static typologies [i.e. birth date] and red flags [i.e. spending amounts] and combine with more dynamic events and practices using new forms of data to increase transaction monitoring.

• digiID PAY is a closed-loop system (having a relationship with both the sender and receiver) that allows us to identify suspicious activity more easily than competing systems.
• digiID PAY’s Customer Due Diligence program collects certain identity details at sign-up while remaining relatively frictionless. Once certain thresholds are met, in compliance with relevant market regulation, digiID PAY will subject users to additional KYC requirements for identity verification.
• digiID PAY conducts a global AML/CTF and Sanctions risk assessment consistent with Financial Action Task Force (FATF) guidance to identify, assess and understand the ML/TF risks digiID PAY faces. This is consistent with a risk-based approach (RBA) which impacts global policy decision-making and implementation of program elements.
• digiID PAY screens accounts and transaction history on a nightly basis, covering the entire customer base. We cross-reference our information against a variety of lists from regulators, governments and more (OFAC's Specially Designated Nationals list, UN Security Council sanctions list, Commission de Surveillance du Secteur Financier in the EU, etc.).

• digiID PAY engages/partners with law enforcement proactively and reactively to both help stop cybercrime while also catching the bad actors that have committed crimes and are under investigation.
  • digiID PAY created a Law Enforcement portal that allows members of organizations around the world to submit case requests, subject to the legal process.
    • We have proactively reached out to law enforcement to make them aware of this system and encourage them to reach out to us with any questions or concerns.
  • On the proactive side, digiID PAY establishes regular training with law enforcement organizations and educates agents on digiID PAY’s systems and the types of crimes that we encounter while also learning from them about the broader ecosystem and the latest trends and movements in global cybercrime.
• From an internal standpoint, we collaborate with various teams across the company (compliance, legal, risk, infosec, etc.) to better identify potential bad actors and make recommendations to agencies