Paycent

AML/KYC Policy



KNOW-YOUR-CLIENT (KYC) & ANTI-MONEY LAUNDERING/COMBATING THE FINANCING OF TERRORISM (AML/CFT) COMPLIANCE POLICY

Know-Your-Client & Anti-Money Laundering Compliance Policy

The following policy has been derived from the general principles, laws, regulations and directives for combating Money Laundering and Financing of Terrorism and exercise an effective Know-Your-Client (KYC) procedures.

  I. Know-Your-Client Program

Texcent Asia Pte. Ltd – Singapore has placed adequate Know Your Customer (KYC) programs. Such essential elements start from the services, risk management and control procedures include, but not limited to:

  • Customer acceptance policy
  • Customer identification

Texcent Asia Pte. Ltd – Singapore is obliged not only to establish the identity of its customers, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account. KYC constitutes a core feature of services’ risk management and control procedures.

 
1. Customer Acceptance Policy

Texcent Asia Pte Ltd maintains clear customer acceptance policies and procedures, including a description of the types of customer that are likely to pose a higher than average risk to an organization. Before accepting account potential client, KYC and due diligence procedures are followed, by examining factors such as customers’ background, country of origin, public or high-profile position, linked accounts, business activities or other risk indicators.

 
2. Customer Identification

Customer identification is an essential element of KYC standards. For the purposes of this paper, a customer includes:

  • The person or entity that maintains an account with the company or registered to company’s product Paycent;
  • Any person or entity connected with a financial transaction who can pose a significant reputational or other risk to the company.

The Company maintains a systematic procedure for identifying new customers and cannot enter into a service relationship until the identity of a new customer is satisfactorily verified. The following is the list of minimum information for account opening with Paycent: 1) Name, 2) Present address, 3) Date and place of birth, 4) Nature of work, 5) Source of funds, 6) Permanent address, 7) Nationality, 8) NIRC, Employment pass ID, Passport number, 9) Contact details, 10) Specimen signature, 11) Selfie holding the ID, and 12) Proof of address.

Texcent Asia Pte. Ltd – Singapore maintains clear standards and policies, on what records must be kept on customer identification and individual transactions.

As the starting point and natural follow-up of the identification process, the company obtains customer identification papers and retain copies of them for at least five years after an account is closed. The company also retains all financial transaction records for at least five years from the date when the client or account holder was terminated, or a transaction was completed.

 
3. Designation of Compliance Officer

Texcent Asia Pte Ltd agrees to formally designate a competent individual to serve as its Compliance Officer. The designated employee should be in a position of responsibility that allows them to implement an effective Anti-Money Laundering Compliance Program.

The Compliance Officer, along with senior management, is responsible for ensuring the ongoing compliance of anti-money laundering laws and regulations.

The Compliance Officers duties will include:

  • ensuring proper compliance training of all staff involved in Paycent activities
  • proper record keeping and reporting as mandated by AMLC
  • maintaining compliance with licensing laws of MAS and ensuring adherence to any related compliance laws or legislation.

The Compliance Officer is also responsible for ensuring that a periodic review is conducted on the quality of the Compliance Program. This review may not be conducted by the Compliance Officer. The review should be done by a senior level employee or qualified professional who understands the requirements of an effective compliance plan.

 
4. Employee Training

A key component of an effective compliance program is employee training. Minimum training must include, how to identify suspicious activity and structured transactions, recordkeeping, recording, and reporting requirements, verifying identification, and familiarity with anti-money laundering forms.

All employees should be required to read this manual and sign a copy of the Acknowledgement of Employee Training that will be retained in their personnel file or Anti-Money laundering files.

 
5. Record Keeping

Texcent Asia Pte Ltd must keep the following records for a period of 5 years with 2 designated officers jointly responsible and accountable:

  • Registered Paycent user’s information and/or identification record safely stored as long as the account is active.
  • All transaction records shall be maintained and safely stored for 5 years
  • Inactive accounts shall preserve and safely store at least 5 years from the date of inactivity.
  • All transactions over SGD1000 – file within 15 days.
  • All suspicious transaction over SGD10,000 including structuring. – file within 15 days.

Structuring/Layering is when a customer sending less than amount to fill out paperwork more than once a day for a combine total of SGD10,000.00 to avoid giving additional information requested.

The following information shall be maintained and required. For verification: 1) Customer name and address; 2) Valid IDs. For record-keeping: 1) Customer Name, 2) Present address, 3) Date and place of birth, 4) Nature of work/name of employer/nature of self-employment or business, 5) Source of funds, 6) Permanent address, 7) Nationality, 8) ID (all valid forms), 8) Contact details, 9) Specimen signature, 10) Type of ID provided, 11) Selfie holding the ID and; 12) Proof of address.

 
6. Independent Review of Paycent

Paycent will conduct an independent review of its compliance program. A senior level employee, or another qualified party such as institution’s attorney or accountant, may conduct the review or by the owner, manager, or employee of the business as long as it is not done by the Compliance Officer.

Whoever conducts the review must be an employee who is familiar with Texcent’s Compliance Program and the anti-money laundering requirements. This will be done at annually.

 
 



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