1. Purpose and limits
This policy sets out the proposed assessment framework for enquiries involving money laundering, terrorist financing, sanctions and related misuse. It is a public summary, not evidence of a regulated licence, a completed independent audit or an implemented transaction-monitoring programme.
FixPays’ precise legal role, jurisdiction-specific obligations and operational responsibilities must be confirmed for the proposed arrangement. Banks, acquirers and other providers may apply their own requirements and make their own decisions.
2. Business and ownership information
Applicants should be ready to identify the operating entity, beneficial owners, controlling persons, authorised representatives and relevant group relationships. Details must be accurate and supported by proportionate, current evidence when requested through an appropriate channel.
The review should establish what is sold, who pays, who receives funds, where customers are located and whether the actual business differs from the website description. Unexplained third-party collections or undisclosed processing for other merchants require clarification.
3. Risk-based assessment
Factors for review can include products, customer markets, delivery times, expected volumes, funding and settlement flows, ownership complexity, prior terminations, disputes and the basis for operating in relevant markets. A high-risk category is not automatically prohibited or automatically acceptable.
Where the circumstances justify it, further information may be required about source of funds, source of wealth, licences, suppliers, customers or the reason for an unusual transaction flow. Requirements must be proportionate to the applicable role and risk.
4. Sanctions, public roles and adverse information
The proposed provider may require sanctions screening, politically exposed person checks and assessment of relevant adverse information. A name match alone should be investigated rather than treated as proof of wrongdoing.
Applicants must not conceal controlling persons, jurisdictions, counterparties or the true purpose of transactions to evade restrictions. No website listing implies that a sanctioned party or prohibited activity will be accepted.
5. Changes and ongoing information
An approved scope, where one is agreed, should specify the relevant entities, domains, activities and markets. Material changes to those details or to payment flows must be disclosed through the agreed process.
Any ongoing monitoring, periodic refresh, transaction review and recordkeeping responsibilities must be allocated in the relevant agreements and operating procedures. This website enquiry form does not itself perform those functions.
6. Concerns and escalation
If information is incomplete, inconsistent or cannot be verified, assessment may require clarification or may not proceed. Refusing an application is not a determination that the applicant committed an offence.
Where a responsible entity has a legal obligation to report suspicious activity, it must act under the applicable reporting and confidentiality rules. This page does not promise that applicants will be notified of reports or investigations, or authorise disclosure that the law restricts.
7. Records and secure submission
Keep the information supplied for assessment accurate and do not alter documents to obtain acceptance. Use only the agreed secure method for sensitive evidence; do not submit passports, payment-card data or customer records through the public contact form.
Applicable recordkeeping periods depend on the responsible entity, service and law. No universal retention period or operational certification is represented by this policy. For an initial question, contact sales@fixpays.com.