Money laundering is defined as the process where the identity of the proceeds of crime is so
disguised
that it gives an impression of legitimate income. Criminals often target financial services firms
through
which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.
In order to combat money laundering and counter terrorist financing (CTF), South Africa has
implemented
the Financial Intelligence Centre Act (FICA) which imposes obligations on financial service
providers.

While cyber pay is currently unregulated and does not fall within the scope of AML/CTF, senior
management
have implemented systems and procedures that meet the standards applicable to regulated
sectors such
as banking. This decision reflects the senior management’s desire to prevent money laundering
and not
be used by criminals to launder proceeds of crime.
ANTI-MONEY LAUNDERING POLICY
The key components of our AML policy and CTF framework include:
• Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of
seniority
and independence, and who has responsibility for oversight of compliance with the relevant
legislation, regulations, rules and industry guidance;
• Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and
management of
money laundering and terrorist financing risks faced by the firm;
• Establishing and maintaining risk-based Customer Due Diligence (CDD), identification,
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verification
and Know Your Customer (KYC) procedures, including enhanced due diligence for customers
presenting a higher risk, such as Politically Exposed Persons (PEPs);
• Establishing and maintaining risk-based systems and procedures for the monitoring of ongoing
customer activity;
• Establishing procedures for reporting suspicious activity internally and to the relevant law
enforcement authorities as appropriate;
• Maintaining appropriate records for the minimum prescribed periods;
• Providing training for and raising awareness among all relevant employees.
SANCTIONS POLICY
Cyber- Pay is prohibited from transaction with individuals and countries that are on prescribed
sanctions lists.
Cyber- Pay will therefore screen against over 1000 sanctions lists including OFAC, FBI Most
Wanted, FATF,
FinCEN & Interpol. Clients are also screened against Domestic Prominent Influenceable Person
(DPIP) &
Foreign Prominent Public Official (FPPO) sources.
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