Last updated: 22 January 2023 

OBJECTIVE OF THE AML POLICY
The Company is fully committed to complying with all relevant laws and regulatory requirements in the international fight against money laundering, terrorist financing and proliferation financing. This policy establishes minimum standards across Orbios Payment Limited for anti-money laundering, counter-terrorist financing and counter-proliferation financing.

The policy applies to all directors and staff (including permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company in Canada or overseas) within the Orbios Payment Ltd and has been created to ensure that the staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

WHAT IS MONEY LAUNDERING AND TERRORIST FINANCING? 
Money laundering is a process through which criminals seek to conceal the true origin, ownership and/or purpose of the proceeds of any criminal activity in order to give the impression that these proceeds originated from legitimate sources.  
Generally, money laundering occurs in three stages:  
A) Placement  
Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments. Such monetary instruments could be: money orders or traveler’s checks, deposited into accounts at financial institutions, dividing the cash into smaller amounts and make various deposits into one or more accounts at one or more banks; Customer opens several accounts in different names at different institutions; employ or persuade others to deposit funds for them; purchasing goods such as jewelry, art and other assets with a view to reselling them at a later date; making deposits with the help of employees of the relevant financial institution.  Cash generated from crime is placed in the financial system. This is the point when proceeds of crime are most apparent and at risk of detection.  
B) Layering  
At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. As example: Selling assets or switching to other forms of investment; transferring money to accounts at other financial institutions; wiring transfers abroad (often using shell companies); depositing cash in overseas banking systems. Once proceeds of crime are in the financial system, layering obscures their origins by passing the money through complex transactions. These often involve different entities like companies and trusts and can take place in multiple jurisdictions.
C) Integration  
Once the origin of the funds has been obscured, a criminal is able to make the funds reappear as legitimate funds or assets.  At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses, for example - an inheritance, loan payments, asset sales abroad.
 Terrorist financing  
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations.  
In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.  
It is important to note distinct characteristics of terrorist financing that can make it even more difficult to detect than money laundering:  
- Terrorists may finance attacks through simple transactions that involve a relatively small amount of money and may be indistinguishable from normal activity;  
- Terrorists may finance attacks using both unlawful and lawful sources of funds, including charitable donations, unlike money laundering where the source of funds is always unlawful; and  
- In terrorist financing, the focus is primarily on the usage of the funds, whether lawfully or unlawfully derived.  
All members of staff are at risk of committing a criminal offence if they assist in a criminal transaction by missing the warning signs.  The Company does not issue preloaded cards or provide services in any way to anonymous Clients or Clients whose identity has not been established and verified in strict abidance with our internal rules and regulations.
The Company does not engage in business activities with shell corporations and shell banks.
In line with PCMLTFA and industry-wide best practices, the Company identifies its potential Clients and their ultimate beneficial owners (UBOs), verifies their identities and performs standard (CDD) or enhanced (EDD) due diligence before the start of a business relationship.  

ORBIOS PAYMENT LTD AML POLICY INCLUDES 
We take the utmost care in ensuring that all our customers are compliant with Anti-Money Laundering (AML) regulations. To this end, our AML procedures include proper identification and verification of each customer, periodical AML trainings for staff, transactions monitoring and risk-based analysis, as well as procedures for reporting suspicious activity internally and to relevant law enforcement authorities. We also establish and maintain a risk-based customer due diligence program which includes enhanced due diligence for those customers who present higher risks. If we find any discrepancies, we are obliged to reject the customer's documents, close the account and terminate the business relationship.