AML software for payment and e-money institutions

• Remote onboarding: customers and merchants are rarely met in person, which raises identity and impersonation risk.
• Speed: payments settle fast, so a check that runs after the payment is often too late.
• Cross-border flows: payments reach many jurisdictions, each with its own sanctions exposure.
• Merchants and agents: a payment business is also responsible for the businesses it lets accept or send payments through it.
• Volume: large numbers of small payments make manual review impossible without good automation.

1. 1

   Onboard customers and merchants

   Pre-onboarding fraud checks, identity verification for individuals, and KYB with beneficial ownership for business customers and merchants.

2. 2

   Screen

   Sanctions and PEP screening of customers, merchants and their owners at onboarding, and of the parties to payments before they are executed.

3. 3

   Monitor

   Re-screening when lists change, and monitoring of transactions for activity that does not fit the customer's profile.

4. 4

   Carry payment information

   Keeping the required originator and beneficiary information with transfers, so that the next institution can screen them too.

5. 5

   Investigate and report

   Reviewing alerts, recording decisions, and reporting suspicious activity to the financial intelligence unit.

The FATF Recommendations apply customer due diligence (Recommendation 10) and PEP measures (Recommendation 12) to payment businesses as to banks, require money or value transfer services to be licensed or registered and supervised (Recommendation 14), and set rules for the information that must travel with wire transfers (Recommendation 16).

In the UK, payment and e-money institutions are authorised by the FCA and are subject to the Money Laundering Regulations 2017. In the EU they are licensed under the national rules implementing the payment services and e-money directives and are subject to the EU anti-money laundering framework. Supervisors generally expect controls proportionate to the firm's risk, and evidence that they work.

• Real-time screening: an API that can sit inline in onboarding and payment flows without holding them up.
• Batch re-screening: the whole customer and merchant base re-checked when lists change.
• Merchant KYB: company checks that reach the beneficial owners and screen them too.
• Explainable matches: every alert shows why it fired, so analysts can clear namesakes quickly at volume.
• Fraud signals before onboarding: cheap checks on email, phone, IP and sign-up behaviour that stop obvious abuse before an identity check is paid for.
• Evidence and deployment: an audit trail of every check, and control over where customer data is processed.