1. Purpose

This policy sets out the guidelines to be followed by NUMAPAY S.R.L. Our KYC policy aims to protect our company and customers from financial crimes like money laundering and fraud.

Our KYC policy outlines the procedures and requirements that we follow to verify the identity of our customers, including the collection of personal information, including but not limited to, such as name, address, date of birth, and identification documents.

KYC is a critical component of our overall risk management framework, and it enables us to establish the identity of our customers, monitor their transactions, and identify any suspicious activity. By implementing a robust KYC policy, we can reduce the risk of our platform being used for illegal activities, safeguard our reputation, and maintain the trust of our customers.

2. Customer information

Prior to entering a relationship with a client, the company collects the following information in an onboarding form:

Individuals:

Full name;
Date of Birth;
Personal Code (if assigned);
Residential address;
Nationality;
Occupation;
Purpose of the business relationship;
Description of the source of funds;
Description of the source of wealth;
ID, Driving Licence or Passport Number;
Tax identification number;
Acknowledgment of reading and understanding T&C;
Confirmation that provided data is correct.

Corporates (clients and business partners):

Entity detail Information (name, contact information, code);
Business Location information (registered and business address);
Legal representatives (e.g. directors) (full name, personal code or date of birth, nationality);
Entity signatory information;
Entity industry;
Legal form;
Purpose of the business relationship;
Description of the source of funds;
Description of the source of wealth;
Tax identification number;
Entity Beneficial Owners;
Annual turnover.

The verification of the information will be carried out either by viewing documentation from the client or via electronic checks.

Electronic checks will include the client’s full name, address, personal code and date of birth from the document and will be carried out by a provider who is registered with the Information Commissioner’s Office, use a range of positive information sources, can access negative information sources and has a transparent process.

2.1 Identifying clients

Whenever the company receives supporting documents related to a new client’s identity, the company needs to be completely satisfied the hat client demonstrates the existence as a real natural or legal person and that they are indeed whom they say they are. Although the Company will at times rely on third-party sources as part of its fact-checking procedure when onboarding clients, the Company bears ultimate legal responsibility for the verification being satisfactory.

Where the identification submitted is incomplete, inaccurate or otherwise insufficient, the company cannot proceed with opening an account for the client submitting such identification.

In more serious cases where money laundering, identity fraud or other crimes are suspected as opposed to simple carelessness or misunderstanding, the MLRO must inform the Oficiul Național de Prevenire și Combatere a Spălării Banilor (ONPCSB).

3. Shell banks

NUMAPAY S.R.L. prohibits the opening and keeping (and dealing with) of accounts of financial institutions operating without the required authorisation or license. NUMAPAY S.R.L. further prohibits any dealings with Shell Banks or businesses that provide services to shell banks.

4. Customer screening

The company will perform Sanctions, PEP, Monitored lists and Adverse media checks.

Veriff will screen the customer‘s name against:

Monitored Lists;
Adverse media;
Sanction;
Politically exposed person.

5. Termination of business relationships with the customer

Where the customer avoids or refuses to submit additional information to NUMAPAY S.R.L. at its request and within the specified time limits, NUMAPAY S.R.L. may, in accordance with internal policies and internal control procedures, refuse to execute monetary operations or transactions and terminate the transactions or business relationship with the customer.