Bank Secrecy Act and Anti-Money Laundering Compliance Program

Last updated: April 6, 2025

Introduction

Payloo Ltd, located at 16 Yekmalyan Street, Yerevan 0002, Armenia, has developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) to ensure compliance with applicable laws and regulations related to anti-money laundering (AML) and counter-terrorist financing (CTF).

The BSA/AML Program Includes:

• Internal policies, procedures, and controls to combat illicit activity and protect customers
• Compliance with AML/CTF regulations in Armenia and other jurisdictions
• Filing Suspicious Activity Reports (“SARs”)
• Filing Currency Transaction Reports (“CTRs”)
• Maintaining comprehensive transaction records
• Designating a Bank Secrecy Act Officer (“BSAO”)
• Executing Know Your Customer (“KYC”) procedures
• Annual independent audits of the program
• Compliance training for all employees

Policies and Procedures

Our BSA/AML Program is approved by our Board of Directors and regularly reviewed to ensure compliance with changing laws and regulations.

Internal Controls

We maintain robust internal policies including employee training, CIP procedures, SAR/CTR filing processes, and independent audits.

Training

• All staff, officers, and board members receive BSA/AML training at least annually
• New employees are trained within 30 days of starting
• Training documentation is recorded and maintained
• Program is updated regularly to reflect regulatory changes

Bank Secrecy Act Officer

The BSAO is responsible for program oversight, filing SARs and CTRs, conducting audits, and reporting directly to the CEO and Board of Directors.

Customer Identification

The Customer Identification Program (“CIP”) helps us verify customer identities, detect suspicious activity, and prevent fraud.

Account Opening Process

Individual Customers

• Email address
• Mobile phone number
• Full legal name
• Government-issued ID number
• Date of birth
• Proof of identity (e.g., passport or driver’s license)
• Home address (no P.O. Boxes)
• Additional documents as required

Non-Armenian customers may need to provide further documentation. If verified, agreements are provided electronically.

Institutional Customers

• Legal name of the institution
• Tax identification number or equivalent
• Legal names and contacts of all signatories and beneficial owners
• Email and mobile number for all signatories
• Principal business address
• Proof of legal existence (e.g., articles of incorporation or business license)
• Contact information for executives and principals
• Proof of identity for individuals owning 10% or more
• Identification information for entity owners owning 10% or more

Once verified, agreements are provided electronically.

Suspicious Activity and Currency Transaction Reports

• SARs are filed when suspicious activity is suspected
• Transactions are monitored for unusual patterns
• CTRs are filed for currency transactions exceeding a set threshold
• Records of all SARs and CTRs are maintained by the BSAO

BSA/AML Program Audit

The Internal Audit function conducts an independent annual assessment of the BSA/AML Program, and results are shared with the Board.

Contact Us

• Email: [email protected]
• Address: Payloo Ltd, 16 Yekmalyan Street, Yerevan 0002, Armenia