AML & KYC Policy

1. Policy Objective

The objective of this policy is to define how Slex Pay identifies, verifies, risk-rates, and continuously monitors merchants and transaction activity. The policy supports legal compliance, financial integrity, and responsible access to payment infrastructure.

2. Scope and Applicability

This policy applies to all merchant categories, including sole proprietorships, partnerships, private limited companies, digital service businesses, online stores, and platform merchants using Slex Pay payment, collection, and disbursement products.

3. KYC and Business Verification Requirements

• Business registration documents, tax references, and legal operating identity.
• Verified ownership and beneficial ownership information.
• Authorized signatory records and identity documents.
• Nature of business, product category, expected volume, and processing profile.
• Bank account details and proof of settlement account ownership.

Slex Pay may request additional information where a merchant category, operating model, or transaction pattern presents elevated compliance risk.

4. Risk-Based Due Diligence

Each merchant is assessed using a risk-based methodology that considers category sensitivity, expected ticket size, transaction geography, settlement behavior, dispute exposure, and ownership complexity. Enhanced Due Diligence (EDD) may be applied for high-risk or control-sensitive cases.

5. Sanctions, PEP, and Adverse-Media Screening

Merchants, owners, and key controllers may be screened against relevant sanctions data, politically exposed persons (PEP) indicators, and adverse media signals. Matches or potential matches are reviewed by compliance personnel before service continuation or activation decisions are made.

6. Ongoing Transaction Monitoring

Slex Pay continuously monitors transaction flows for unusual behavior, including but not limited to rapid volume spikes, suspicious velocity patterns, structuring indicators, mismatch between declared and observed activity, repeated failed authorization behavior, and abnormal refund/dispute concentration.

• Automated and manual monitoring controls may run concurrently.
• Alerts may trigger temporary review actions or documentation requests.
• Merchants must provide timely clarification when requested.

7. Escalation, Restrictions, and Reporting

Where suspicious or non-compliant activity is identified, Slex Pay may apply proportionate controls including enhanced review, temporary settlement restrictions, account-level limits, or service suspension. Where legally required, suspicious activity may be reported to competent regulatory or enforcement authorities through appropriate channels.

8. Merchant Cooperation Obligations

• Keep KYC and business profile information accurate and up to date.
• Provide requested documents and clarifications within communicated timelines.
• Notify Slex Pay of material business changes, control changes, or category changes.
• Maintain internal controls preventing misuse of accounts and payment flows.

9. Record Retention

KYC, transaction, and monitoring records are retained according to applicable legal and regulatory requirements, internal policy standards, and partner compliance obligations. Retention periods may extend where investigation, audit, legal hold, or regulatory review is active.

10. Policy Governance and Updates

This policy may be updated from time to time to reflect changes in law, regulatory guidance, payment-network standards, or internal risk policy improvements. Continued use of Slex Pay services indicates acceptance of the most current published policy.