AML & KYC Policy

AML and KYC Policy

Effective January 01, 2020

This AML and KYC policy is designed to prevent or counter illicit financing of terrorism and money
laundering by complying with the laws and requirements of national and international laws
through the introduction of a Merchant identification procedure.
This policy is posted on this web resource and included in other contracts concluded with the
Merchant and shall enter into force together with the General Agreement.

1.      Terms and Definitions

1. 1. As used in this AML and KYC Policy, the following terms that can be found on third-party
links of the Pay2Bee web resource shall have the meanings set forth below:
AML (AML CFT CWMDF) and KYC Policy and/or Policy means anti-money laundering and
counter-terrorist financing and counter-weapons of mass destruction financing. This policy is
designed to counteract the laundering of proceeds from crime and is intended to prevent and
mitigate possible risks of the Company being involved in any kind of illegal activity.
KYC – Know Your Customer. It is an operating principle of financial institutions, which requires
them to verify the identity of their customers before carrying out any financial transaction.
CIP – Customer Identification Program. This program provides requirements for financial
companies in identifying individuals who wish to use their services for financial transactions). This
program is administered by the US Department of Justice.
Merchant and/or Related Parties (or you) means any legal entity or individual who has
expressed interest in using our services, uses them or has previously used them or is otherwise
related to the services provided by the Company, i.e. is a family member, beneficial owner,
representative of the Merchant’s company, etc.
Prohibited Conduct means any manifestation of illegal conduct, which includes fraud, corruption,
money laundering, conspiracy, terrorist financing, and any other illegal conduct within the meaning
of the applicable legislation.
Fraud means the use of fraudulent acts or words with the intention to pursue personal motives and
interests, thereby harming the interests of other users and Pay2Bee.
Corruption means an act of offering, demanding, soliciting or receiving anything of value to
influence improperly the actions and rights of any other party.
Money Laundering means a financial transaction scheme that aims to conceal the identity, source
and/or destination of illegally gained funds.
Conspiracy means an agreement between two or more persons aiming to influence improperly the
actions and rights of any other party or persons, including Pay2Bee.
Terrorist Financing means the collection or provision of funds by any means that will directly or
indirectly influence illegal actions under the applicable law.
Criminal Conduct means a crime committed anywhere in the world.
Anti-Fraud Commissioner means a person authorized to monitor, prevent and, if necessary,
conduct an investigation to identify the Prohibited Conduct. The person above shall be directly
responsible for the proper implementation of the policy by all suspects.

1.2. You can find the above terms on third-party links on the Pay2Bee website.

1.3. Terms not defined in this policy shall have the meanings set forth in the General Agreement.

1.4. In this AML and KYC Policy, the name Pay2Bee and all the pronouns “we”, “us”, “our” will refer
to Pay2Bee, including its founders, developers, directors, investors, employees, and persons
specified in this Policy.

1.5. Depending on the context, Pay2Bee may also refer to services and products, websites, and other
materials provided by Pay2Bee.

2. Legal Framework

2.1. This Anti-Money Laundering Policy is based on the following laws and regulations: the laws of
the Republic of Lithuania and the European Union, FATF recommendations, which include but are
not limited to the following regulations:

2.1.1.the Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist
Financing, which regulates and determines the implementation of and compliance with various
special procedural measures to prevent money laundering and terrorist financing and determines
the scope of obliged entities, their duties, rights and responsibilities. The law reflects the
requirements of Directives 2005/60/EC and 2006/707/EC of the European Union, which have been
adapted to the regulatory acts of the Republic of Lithuania and supplemented by national

2.1.2. Regulations No.125 for Enhanced Customer Due Diligence of the Financial and Capital Market
Commission, dated August 27, 2008. The Regulation has been adopted in accordance with the Law
on the Prevention of Money Laundering and Terrorist Financing and determines the cases when
financial institutions must conduct enhanced customer due diligence, the procedure for and
minimum extent of the enhanced due diligence, categories of risk of laundering the proceeds from
crime (money laundering) and of terrorist financing and the relevant risk characteristics, special
measures of enhanced customer due diligence, and the procedure for enhanced monitoring of
customer transactions.

2.1.3. Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on
the prevention of the use of the financial system for the purpose of money laundering or terrorist

2.1.4. International Convention for the Suppression of the Financing of Terrorism (1999).

2.1.5. FATF Forty Recommendations.

2.1.6. Other international instruments governing the prevention of money laundering and terrorist

2.2. The adherence to and acceptance of Pay2Bee’s AML and KYC Policy shall automatically imply
compliance with all laws and regulations.

3.      KYC Procedure

3.1. The KYC procedure implements the recommendations of the FATF (Financial Action Task
Force). According to the above recommendations, a person engaging in financial transactions must
confirm his/her identity.

3.2. KYC is a procedure to identify and verify the Merchant’s identity. In the process of collecting
information about the Merchant, Pay2Bee must make sure that the person who contacted the
Company has a real address of residence, was not convicted or not involved in activities that would
cast doubt on the legality of the origin of his/her/its funds.

3.3. In relation to the Merchant, a CIP procedure may be carried out for identification purposes,
which shall consist of collecting the following customer data:

3.3.1. In case of a corporate Merchant:
– Company registration number in the official register of legal entities of the country of the
company’s registration.
– Company name.
– Registration address and business address of the company.
– List of authorized persons.
– Corporate structure.
– Information about business partners and upcoming transactions (including contracts).
– Details of UBOs (owner and beneficiary) and KYC/AML check results in respect of them (money
laundering risk assessment related to customers).

3.3.2. In case of an individual Merchant:
– Full name.

– Date and place of birth.
– Place of residence.
– TIN.

3.4. The Merchant shall provide the Pay2Bee Company with supporting documents confirming the
details of the Merchant, namely:
– International or domestic passport.
– Proof of the place of residence and registration.
– Phone bills.
– Bank statements.
– Copies of utility bills.
– Other documents confirming the information provided by the Merchant for identification

3.5. Pay2Bee shall have the right to request additional documents necessary for identification of the
Merchant, at its discretion.

4.      User Identification

4.1. Pay2Bee reserves the right to take all possible measures, including forced user identification
request, to prevent money laundering, terrorist financing and other illegal activities by tracking
Merchant’s suspicious activities. This refers to activities that are suspected to constitute or show
any signs of Prohibited Conduct set out in the Policy.

4.2. Pay2Bee shall not track each user personally, but nevertheless, the Company shall check the
Merchants caught engaging in suspicious or illegal activities.

4.3. We may request, at our discretion, additional evidence of identification if the Company has any
suspicions concerning the Merchant’s activities, for any reason.

4.4. Pay2Bee reserves the right to freeze an account associated with any suspicious activity without
notice and require that the owner of the respective account must complete a KYC user verification

5.      Personal Data Use and Processing

5.1. All personal data of customers, users and other persons suspected of terrorist financing, money
laundering or fraudulent activities will be used and protected in accordance with Pay2Bee's

6.      Transaction Monitoring

6.1. Pay2Bee shall carefully monitor all Merchant’s transactions if the Merchant is suspected of a
fraud or illegal activities. If any such activities are detected, the Merchant must undergo a KYC
identity verification procedure. If the Merchant refuses or ignores the request, Pay2Bee reserves
the right to freeze the Merchant’s account and block access to it until the conflict is resolved.

7.      Amendments and Modifications

7.1. The AML and KYC Policy may be modified at any time, at the option and discretion of Pay2Bee.
The Merchant acknowledges that it is in the Merchant’s interests to independently track and verify
changes in the AML and KYC Policy from time to time and carefully read notifications of
amendments to this Policy.

7.2. If the Merchant does not wish to accept the AML and KYC Policy, the Merchant should not
continue to use the services of Pay2Bee. The further use of the Pay2Bee web resource and the
Company’s services after the amendments to this Policy have entered into force will automatically
be regarded as acceptance of these amendments by the Merchant.

8.      Anti-Fraud Policy

8.1. The anti-fraud policy shall be an integral part of the Pay2Bee General Agreement, which shall
consist in preventing or partially containing fraud, corruption, conspiracy, money laundering,
terrorist financing and other illegal activities in Pay2Bee’s operations.

8.2. Pay2Bee is committed to high legal, ethical and moral standards. Therefore, the Merchants and
partners of Pay2Bee have every right to expect that the Company will implement a significant level
of protection against any illegal activity.

8.3. This policy has been integrated in accordance with applicable international and local laws.

9.      Fraud Investigation

9.1. If a person is reasonably and justifiably suspected of being directly or indirectly involved in
terrorism, terrorist financing, money laundering or fraud, Pay2Bee reserves the right to thoroughly
investigate the person using all legal methods and means set out in the legislation and in the
General Agreement and in integral parts of (Annexes to) the General Agreement.

9.2. The Anti-Fraud Commissioner shall be the person responsible for detecting, investigating, and
protecting against illegal activities.

9.3. In some cases, Pay2Bee reserves the right to engage third parties to investigate individuals for
the purpose of collecting sufficient evidence to transfer them to competent authorities.

9.4. The Anti-Fraud Commissioner shall also be responsible for:

9.4.1. Collecting and storing any information related to the case of the alleged suspect, including
information about merchants and transactions;

9.4.2. Reporting his/her findings to Pay2Bee and competent authorities and third parties if such
information is required to be provided for investigation purposes.
The Anti-Fraud Commissioner shall have the full right to prosecute, open and close and report any
investigation of the Prohibited Conduct within his/her competence without prior notice, consent
and/or interference from the suspected person or organization. All investigations shall be
conducted in a strictly impartial and confidential manner.

9.5. Pay2Bee reserves the right to block the Merchant's account and all of the Merchant’s funds until
the circumstances are clarified in order to ensure an expeditious and complete procedure for such
All merchants under the General Agreement, including its integral parts, shall cooperate with the
Anti-Fraud Commissioner as quickly and efficiently as possible and, in particular, provide relevant
information and documentation if the Commissioner so requests.

9.6. All documents and information collected and created during the investigation of Prohibited
Conduct of a suspect shall be kept strictly confidential. The information shall be kept secret in the
interests of the persons involved, third parties and in the interests of the investigation’s integrity. 

9.7. The Anti-Fraud Commissioner shall only disclose confidential information to those individuals
or companies who are authorized to receive it if necessary for the purpose of conducting an
investigation or assisting in an investigation.

10.  Responsibilities of the Parties

10.1. The Anti-Fraud Commissioner shall be responsible for monitoring, investigating and
preventing Prohibited Conduct or illegal conduct.

10.2. According to the above, the Company reserves the right to perform the identification of any
user or transaction in accordance with the KYC policy in order to identify evidence of prohibited

10.3. Pay2Bee shall be responsible for:

10.3.1. Taking appropriate action against persons who are suspected of a crime or have committed
a crime;

10.3.2. Developing and maintaining effective internal controls to prevent illegal activities;

10.3.3. Conducting operational investigations if detecting prohibited conduct or illegal activities;

10.3.4. Reporting any suspicious activity and persons to relevant state authorities and competent

10.3.5. Ensuring that the Anti-Fraud Commissioner reports on any internal or external suspicious
activities and incidents involving illegal activities.

11.  User Statement

11.1. You guarantee that using the service of Pay2Bee you have no intention to perform any
prohibited actions described above. In addition, you agree to any checks in connection with an
investigation under the Policy and you agree to cooperate fully and promptly with the Anti-Fraud
Commissioner as part of the investigation.

12.  Amendments

12.1. The AML and KYC policy may be amended at any time, at the discretion of Pay2Bee. By
accepting the terms and conditions of this policy, you acknowledge and agree that you assume the
responsibility to periodically check the Policy and its terms and conditions and receive notifications
of any changes.

12.2. If you do not wish to accept any amendments to the Policy, you should not continue to use the
services of Pay2Bee. The further use of the services after the adoption and entry into force of the
amendments shall imply the automatic acceptance of the terms and conditions.
If you have any information about illegal activities or suspicious individuals, please contact our
support team at [email protected]