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Statement of Anti Money Laundering Policy


It is Alternative Payments Limited’s policy to ensure that our company, its senior management and all of our company’s employees are committed to complying with all legislation and appropriate guidelines designed to combat money laundering activity, the funding of terrorism or criminal activity in the jurisdiction in which we operate.

Alternative Payments Limited is registered for Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) purposes with the Isle of Man Financial Services Authority under Registration Number DB000107. For any queries relating to Anti Money Laundering please e-mail us on compliance@creditvouchers.com. For other ways to get in touch, please see our website at www.CreditVouchers.com.

We will:

  • Take reasonable steps to establish the identity of any person or company for whom it is proposed to provide any services where applicable
  • Retain identification and transactional documentation as required by the legislation in the jurisdiction in which we operate
  • Provide initial and on-going training to ensure all relevant staff are aware of their personal responsibilities and the anti-money laundering procedures in respect of identifying clients, monitoring, record-keeping, remaining vigilant at all time and reporting suspicious transactions
  • Develop and maintain all necessary or advisable AML/CFT policies and procedures in line with evolving statutory and regulatory obligations from enforcement agencies
  • Report to the relevant authority where there are reasonable grounds to suspect that a money laundering offence has been committed
  • We will at all times ensure the protection of our staff, and safeguard our organisation and reputation against the threat of money laundering and the funding of terrorist and criminal activities.

Alternative Payments Limited will do all it can to prevent the company and its staff being exposed to money laundering, identify the potential areas where it may occur, and to comply with all legal and regulatory requirements, especially with regard to the reporting of actual or suspected cases.


Key Issues

Alternative Payments Limited is committed to the prevention, detection and reporting of money laundering. All employees must be vigilant for the signs of money laundering. Any employee who suspects money-laundering activity must report this promptly to our Money Laundering Reporting Officer.


1. Introduction

Alternative Payments Limited is a "Designated Business" for the purposes of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2015, which came into operation on 1st April 2015 and constitutes the core regulations applicable to the way Alternative Payments addresses AML/CFT risks under the Proceeds of Crime Act 2008 (“POCA”) and the Terrorism and Other Crime (Financial Restrictions) Act 2014. Alternative Payments Limited seeks to minimise the likelihood of money laundering or terrorist financing occurring by putting in place proper AML/CFT policies and procedures.

Our AML/CFT policies and procedures have therefore been adopted in order to introduce safeguards to help identify and report on instances where money laundering is suspected.


2. Scope of our policies and procedures

Formal AML/CFT policies and procedures apply to all employees of Alternative Payments Limited and aim to maintain high standards of conduct by preventing criminal activity through money laundering. The policies and procedures set out the procedures, which must be followed (for example the reporting of suspicions of money laundering activity) to enable Alternative Payments Limited to comply with its legal obligations.


3. What is Money Laundering?

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the Isle of Man (Section 139 of POCA); entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (Section 140 of POCA); and acquiring, using or possessing criminal property (Section 141 of POCA).

There are also two secondary offences, failure to disclose any of the three primary offences above; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

Any member of staff could potentially be caught by the money laundering provisions if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. Our policies and procedures set out how any concerns should be raised.

It is important that all employees are familiar with their responsibilities as serious criminal sanctions may be imposed for breaches of the legislation. The key requirement of employees is to promptly report any suspected money laundering activity to the Money Laundering Reporting Officer.

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