Overview
Payoup is a technology platform (SaaS) operated by Enexfi LTD that acts as the principal seller (Merchant of Record) on all transactions. Payoup provides service providers with the commercial, technical, and payment infrastructure to sell and grow globally. Payment processing and payout services are provided through regulated third-party payment service providers, while Payoup applies appropriate AML, CTF and sanctions compliance controls within its platform environment.
This policy outlines the procedures and controls we implement to detect, prevent and report suspicious activities on our platform. All users must comply with this policy as a condition of using Payoup services.
Role of Payoup
Payoup does not independently provide regulated payment services. The company relies on regulated payment partners for payment processing activities, while maintaining platform-level controls including user verification, prohibited activity monitoring, and compliance reviews.
Scope & Applicability
This policy applies to:
- All registered service providers on the Payoup platform
- All clients who purchase services or make payments through the platform
- All platform transactions and payout-related activities facilitated through Payoup's integrated payment providers
- All Payoup employees, contractors and agents involved in platform operations
KYC/KYB Verification
All users must complete identity verification before accessing payment features. Payoup applies a structured approach to customer due diligence:
Identity Verification (KYC)
All service providers must provide government-issued photo identification, proof of address and contact details. Identity documents are verified through internal verification processes and/or third-party verification providers before payout features are activated.
Business Verification (KYB)
Service providers operating as registered businesses must provide company registration documents, beneficial ownership information and proof of business address. All business accounts undergo enhanced verification.
Ongoing Due Diligence
We continuously monitor account activity and may request updated documentation periodically. Users with significant changes in transaction volume or activity patterns may be subject to additional verification.
Enhanced Due Diligence (EDD)
Users in certain jurisdictions or with unusual transaction patterns may be subject to enhanced due diligence measures including additional documentation requirements and more frequent reviews.
Prohibited Activities
The following activities are strictly prohibited on the Payoup platform:
- Using the platform to launder proceeds of crime or to disguise the origins of illegally obtained funds
- Financing or providing material support to terrorist organizations or activities
- Structuring transactions to avoid reporting thresholds or detection (smurfing)
- Creating fake invoices, fictitious services or sham transactions to move money
- Using another person's identity or account to conduct transactions (identity fraud)
- Conducting transactions on behalf of sanctioned individuals, entities or countries
Prohibited Relationships
Payoup strictly prohibits the establishment or maintenance of business relationships with the following categories of entities and individuals:
- Opening or maintaining anonymous accounts or accounts in fictitious names. All accounts must be linked to a verified, real identity.
- Opening or maintaining accounts for unlicensed banks and/or non-bank financial institutions (NBFIs) that are not properly authorised by a recognised regulatory authority.
- Dealing with other entities that provide banking or payment services to unlicensed banks or NBFIs.
- Establishing or maintaining accounts or relationships with shell banks (banks that have no physical presence in any country where they are incorporated and licensed, and are not affiliated with a regulated financial group).
- Dealing with another entity that is known to provide services to shell banks.
- Opening or maintaining accounts for entities designated under Section 311 of the USA PATRIOT Act as institutions of primary money laundering concern.
- Opening or maintaining accounts for unlicensed or unregulated remittance agents, exchange houses, casa de cambio, bureaux de change or money transfer agents that are not properly registered and supervised by a competent authority.
- Payoup assesses the risks associated with relationships involving domestic and foreign Politically Exposed Persons (PEPs), including their family members and known close associates, and applies enhanced due diligence measures where such relationships are identified.
Transaction Monitoring
Payoup employs a combination of automated and manual monitoring to detect suspicious activity related to supplier payment requests and platform usage:
Automated Screening
Transactions and supplier-payment-related activities are reviewed through automated screening tools and manual compliance reviews where appropriate. Our systems flag unusual patterns for further review.
Threshold-Based Alerts
Supplier payment requests exceeding certain volume or frequency thresholds trigger automatic review. These thresholds are regularly updated based on platform assessments.
Behavioral Pattern Analysis
We analyze supplier payment patterns including rapid supplier payment requests, inconsistent service descriptions, pricing anomalies and geographic factors.
Manual Review
Flagged supplier payment requests are reviewed by our compliance team. Reviews may result in additional information requests, supplier payment holds or account restrictions.
Sanctions Screening
Payoup screens all users and transactions against major international sanctions lists, including:
- UK HM Treasury Sanctions List
- US OFAC Specially Designated Nationals (SDN) List
- EU Consolidated Sanctions List
- United Nations Security Council Sanctions List
- Other applicable national and regional sanctions regimes
Sanctions screening is performed at onboarding and on an ongoing basis. Users or transactions matching sanctions entries will be immediately blocked pending investigation.
Reporting Obligations
Payoup maintains clear reporting procedures for suspicious activities:
Internal Reporting
All employees are trained to identify and escalate suspicious activity to the designated compliance contact. Internal reports are documented and investigated promptly.
Regulatory Reporting
Where legally required and applicable, suspicious activity reports may be submitted to the relevant authorities or through applicable regulatory channels. We do not inform the user when a report has been filed (tipping off prohibition).
Law Enforcement Cooperation
We cooperate fully with law enforcement agencies and regulatory bodies in connection with investigations related to money laundering, terrorist financing or sanctions violations.
Enforcement Actions
When suspicious activity is detected or a policy violation occurs, Payoup may take any of the following actions:
Transaction Freeze
Immediate hold on pending transactions and supplier payment requests while an investigation is conducted.
Account Suspension
Temporary restriction of account access pending completion of an investigation or receipt of additional documentation.
Account Termination
Permanent closure of accounts found to be involved in prohibited activities. Remaining funds may be held as required by applicable law.
Regulatory & Legal Referral
Referral to relevant law enforcement or regulatory authorities for further action where criminal activity is suspected.
Client Exit & Re-establishment
Payoup maintains defined procedures for exiting client relationships where financial crime risk is identified:
Exit Process
When a decision is made to terminate a customer relationship due to financial crime concerns, the exit process is applied consistently across the entire entity, including any foreign branches and affiliates. The process includes documentation of the reason for exit, secure closure of all associated accounts, and retention of all relevant records.
Re-establishment Controls
Payoup maintains controls to identify customers who were previously exited for financial crime reasons if they seek to re-establish a relationship. Previously exited customers are flagged in our internal systems, and any attempt to open a new account or relationship is subject to enhanced review and senior management approval before onboarding.
Cross-Entity Consistency
The client exit policy applies uniformly across all business lines, geographic locations, and operational entities of Payoup and its parent company Enexfi LTD, ensuring no inconsistency in the treatment of financial crime-related exits.
Screening & Internal Watchlists
Payoup operates comprehensive screening processes and maintains internal watchlists to identify and manage financial crime risks:
Sanctions Screening
All customers and transactions are screened against international sanctions lists (OFAC SDN, UK HMT, EU Consolidated, UN) at onboarding and on an ongoing basis. Potential matches trigger immediate blocking and escalation to the compliance team.
PEP Screening
All customers are screened for Politically Exposed Person (PEP) status, including domestic and foreign PEPs, their family members, and known close associates. Identified PEPs are subject to enhanced due diligence and senior management approval.
Adverse Media / Negative News
Customers are screened against adverse media and negative news sources at onboarding and periodically thereafter. Significant adverse findings trigger enhanced review and potential escalation.
Internal Watchlists
Payoup maintains internal watchlists of previously exited customers, flagged individuals, suspicious actors, and entities associated with financial crime concerns. These lists are updated continuously and consulted during onboarding and ongoing monitoring processes.
Risk Tolerance
Payoup has defined a Risk Tolerance Statement that establishes clear risk boundaries around its business operations:
Risk Appetite Statement
Payoup operates a low risk appetite for financial crime. The entity will not knowingly onboard or retain customers who present unacceptable financial crime risks, including but not limited to money laundering, terrorist financing, sanctions evasion, bribery, or corruption.
Risk Boundaries
The risk tolerance framework defines acceptable customer types, geographic exposure, product/service risk levels, and transaction thresholds. Activities or relationships that fall outside these boundaries are subject to enhanced scrutiny, escalation, or rejection.
Annual Review
The risk tolerance statement is reviewed and approved by senior management at least annually, or more frequently when triggered by significant regulatory changes, emerging risks, or material changes in business activities.
Record Keeping
In compliance with applicable regulations, Payoup retains the following records:
- Customer identification and verification records for a minimum of 7 years after the business relationship ends
- Transaction records for a minimum of 7 years from the date of the transaction
- Internal suspicious activity reports and investigation outcomes
- All correspondence with regulatory authorities regarding AML/CTF matters
Policy Updates
This policy is reviewed and updated at least annually, or more frequently when required by changes in legislation, regulatory guidance or platform operations. Users will be notified of material changes via email and platform announcements. Continued use of the platform constitutes acceptance of the updated policy.