Payment and E-Money Institutions

A payment institution is a market participant licensed by the jurisdiction supervisor that provides payment services. It can perform money remittances, payment transactions, direct debit or credit transfers, provide cash deposit, cash withdrawal or payment initiation services, etc. A payment institution cannot accept deposits from unprofessional market participants or issue electronic money. In addition to payment services, it has the right to provide additional services that are closely related to these services, e.g. currency exchange.

An electronic money institution is a market participant licensed by the jurisdiction supervisor, which has the right to issue electronic money. Electronic money is pre-paid monetary value issued into circulation by an electronic money institution, held on electronic devices, which can be used for payment purposes. An electronic money institution may also perform money remittances, payment transactions, provide cash deposit and withdrawal services, perform direct debit or credit transfers, etc.

Сompliance Program for Your Business

Failure to have an effective anti-money laundering and counter-terrorism and counter-proliferation financing (AML/CTF/CPF) compliance program has seen financial intelligence units (FIUs) hand out record fines in the tens of millions of dollars against organizations.

We can help you to build an effective AML/CTF/CPF compliance program. Our specialists will implement tools and processes to protect your organization from high-risk customers and transactions. These components include internal processes and procedures, such as policies, training and risk management, as well as tools, including sanctions list screening, transaction monitoring, risk scoring and regulatory reporting.

Sanctions compliance program for your business

Staying compliant with sanctions regulations is more complex and challenging than ever. Regulatory guidance clearly states that simply screening transactions is not enough. In the face of these complexities, it’s crucial to regularly evaluate your supply chain and trade operations, in order to make sure that your company is meeting compliance expectations. Both the supply chain and global trade operations are extremely complex and require a thoughtful sanctions setup. Sanctions compliance is based on strict liability, and no set of actions provides a safe harbour from enforcement action.

Our specialists will help to evaluate what your company is doing to monitor its supply chain, customers, shipments. We also help in managing international sanctions regulations and closing compliance gaps in transaction monitoring and filtering programs.

Developing Internal Policies and Procedures

To defend the market from criminal enterprises, drug dealers, corrupt public officials, sanctions violations and terrorists, governments came up with a counter-move –you must document your company’s AML/CTF/CPF and sanctions policies and procedures that have to be adopted by all financial businesses. It's a critical element of a successful compliance program, which allows you to mitigate risks of your company's possible involvement in illegal activity.

Our company will help plan your AML processes based on the requirements of the regulator of the jurisdiction of your company and standards of the jurisdictions where you do business. Our specialists ensure you have in place procedures for onboarding new customers, performing customer due diligence, monitoring transactions and investigating suspicious activities, record keeping of AML processes, as well as other necessary internal documents. Also we can help you with necessary documents, forms for application, KYC reports, Suspicious Activity reports development, etc.

Maintenance of an AML/CTF/CPF and Sanctions violation Programs

A review by the independent party is a great way to spot the weaknesses of the company’s risk assessment and compliance program: KYC due diligence procedures, compliance training, monitoring, compliance with sanctions regimes and reporting systems. Our specialists can help you in several critical areas, such as:

Reviewing company policies to ensure they align with existing regulations
Carrying out frequent risk assessments to identify new and emerging areas of risks in order to implement preventive or corrective strategies to address compliance issues
Performing ongoing monitoring of operations and procedures of the different sections of your institution to ensure overall compliance
Ensuring that Your Know Your Employees and Know Your Customers programs meets the size, complexity and geographic reach of your institution
Developing and evolving your procedures for the handling and resolution of policy violations
Performing periodic independent testing of the effectiveness of the AML/CTF/CPF
Sanctions violation programs

Applying Due Diligence – KYC, CIP, CDD and EDD for customers and partners

Knowing your customers is an integral part of an AML program. There are many terms used including, know your customer (KYC), customer due diligence (CDD) and enhanced due diligence (EDD). These KYC measures are meant to protect your business entity, especially if your business is vulnerable to high money laundering and terrorism financing risk. It really boils down to the risk assessment of your business and how well you mitigate them by employing appropriate controls.

Our company can perform on your demand KYC, CIP, CDD and EDD for your customers and partners. Within the framework of this service, a customer or partner also is checked for compliance with the Politically Exposed person status and being placed in international sanctions lists. The final research report and recommendations of our specialists for the client or partner will be prepared and compiled in accordance with your internal regulatory policies and procedures, which will greatly facilitate the work of your in-house Compliance department.

Screen Against Watch and Sanctions Lists

In most jurisdictions, institutions are required to screen new customers against sanction lists as well as lists of known high-risk individuals (suspected terrorists, narcotics traffickers, etc.) for potential matches. When a company encounters a potential “sanction match” or “sanctions hit”, it must investigate further with additional information to evaluate whether the similarities in the text reveal a true sanctions exposure.

Our company can perform on your demand Screen Against Watch and Sanctions Lists, and in case of a coincidence, our experts will investigate. The final research report and recommendations of our specialists for the client or partner will be prepared and compiled in accordance with your internal regulatory policies and procedures, which will greatly facilitate the work of your in-house Compliance department.

Consultation services

Our experts can advise you in relation to specific compliance queries and structuring issues or support your in-house Compliance department.

We can consult you and help in preparation of training programs, tests for checking the knowledge of employees, documents recording internal training with employees in accordance with the requirements of supervisory authorities in AML/ CFT/CPF and Sanctions legislation.

Also, at your request, we can assist in the preparation of responses to inquiries, requirements, submissions, orders of supervisory authorities, correspondent banks or other organisations in the field of AML/CFT/CPF and related issues.

Fraud & Chargeback/Dispute Risk Assessment

When considering the risk faced by organizations, it is helpful to analyze significant inherent risks and residual risks. The main risk factors are:

the nature of the business (industry)
the operating environment (domestic, cross-border operations)
the effectiveness of your team and systems (preventive and detective controls)
your company and employees value.

The benefits of conducting a risk assessment include enabling the company to:

improve communication and awareness about fraud & chargeback/dispute
identify where your business is most vulnerable to fraud & chargeback/dispute and what activities put it at the greatest risk
know who puts your business at the greatest risk
develop plans to mitigate risk
develop techniques to investigate and determine if fraud & chargeback/dispute has occurred in high-risk areas
assess internal controls
comply with regulations and professional standards

Fraud & Chargeback/Dispute Risk Management

Risk management involves the identification, prioritization, treatment, and monitoring of risks that threaten a company. Risk management balances risk appetite.

Risk management programs must incorporate internal documentation designed to do all of the following: risk prevention activities, risk detection activities and respond to identified risk.

All aspects of the risk management program should be continuously monitored to ensure they address a company’s current needs and risks, as well as to reflect management’s ongoing commitment to preventing, detecting and investigating risk.

Legal services for business

Our top quality legal support and original solutions on complex legal issues, are served by applying innovative methods and creative thinking in a way that creates added value for our clients. We understand that each client is different and therefore ensures that we can quickly understand your needs in legal support and provide advice and solutions that are tailored to your individual circumstances.We provide legal support for your Compliance which also can include Developing and Harmonization of the Agreements, with your customers or partners before you have established business relationship with them. The service we offer covers also all associated steps in the process, from identifying weak spots in your company's legal side, carrying out the valuation of your legal side of business and through to finalizing your business legal side to necessary levels.