Anti-Money Laundering Policy

It is DYNAPAY 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 terrorist or criminal activity in the jurisdictions in which we operate.

We will:

  • Take reasonable steps to establish the identity of any person for whom it is proposed to provide any services where applicable.
  • Retain identification and transactional documentation as defined in the legislation in the jurisdiction in which we operate
  • Provide initial and ongoing 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
  • Ensure our Policy is developed and maintained 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 organization and reputation against the threat of money laundering and the funding of terrorist and criminal activities.
Risk Assessment

Our business activity is based on the following principles and markets:

  1. No financial transactions or money handling will be undertaken by DYNAPAY LIMITED, other than the charges made for the services outlined above.
  2. DYNAPAY LIMITED does not offer any Banking, Accounting or Secretarial services.
Key Issues

DYNAPAY 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 the Money Laundering Reporting Officer, or Deputy Money Laundering Officer.

1. Introduction

The Proceeds of Crime Act 2002 (POCA) consolidated, updated and reformed criminal law with regard to money laundering DYNAPAY LIMITED will take reasonable steps to minimize the likelihood of money laundering occurring by putting in place proper policies and procedures.

This policy has therefore been adopted in order to introduce safeguards to help identify and report on instances where money laundering is suspected.

2. Scope of the Policy

This Policy applies to all employees of DYNAPAY LIMITED and aims to maintain the high standards of conduct, by preventing criminal activity through money laundering. The policy sets out the procedures, which must be followed (for example the reporting of suspicions of money laundering activity) to enable DYNAPAY 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 UK (Section 327 of the Act); 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 328 of the Act); and acquiring, using or possessing criminal property (Section 329 of the Act).

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. This Policy sets out how any concerns should be raised.

While the risk to Web-Merchant Services Ltd of contravening the legislation is low, 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.