How Monerails prevents money laundering, terrorist and proliferation financing, and applies international financial sanctions.
{{ para }}
{{ para }}
How Monerails prevents money laundering, terrorist and proliferation financing, and applies international financial sanctions.
This policy sets out the principles and controls Monerails applies to prevent its services from being used for money laundering, terrorist financing, financing the proliferation of weapons of mass destruction, bribery, fraud or sanctions evasion (together, "financial crime").
Monerails has zero tolerance for the use of its services for these purposes. We would rather decline a business relationship than accept a risk we cannot manage.
Monerails is operated by Rollo Technologies Inc., a Delaware corporation (United States). Monerails is a technology company: it is not a bank, a payment institution or an electronic money institution, and it does not hold customer funds.
Collections, payouts, balances, foreign exchange and card issuing are executed by regulated partner institutions in the countries concerned. These partners remain subject to their own anti-money laundering and counter-terrorist financing (AML/CTF) obligations and to the supervision of their authorities. Monerails applies this programme in addition to those obligations, not instead of them.
This policy applies to every Monerails business customer, their directors, beneficial owners, users and cardholders, and to all Rollo Technologies Inc. staff and contractors who work on Monerails.
Our programme is built on international standards and takes into account the regional frameworks of the countries where our customers operate:
Listing these frameworks describes the references of our programme. It does not mean that Monerails or Rollo Technologies Inc. is licensed, registered or supervised by any of these authorities.
The management of Rollo Technologies Inc. approves this policy and provides the resources needed to apply it.
A Compliance Officer, appointed by management, runs the programme, approves high-risk onboarding decisions, reviews alerts and unusual activity, decides on reports and reports regularly to management. The Compliance Officer has the independence and access to information the role requires.
Every member of staff must follow this policy and report any suspicious situation to the Compliance Officer without delay.
We assess and document the financial crime risks Monerails is exposed to, and we scale the intensity of our controls to the level of risk. This assessment is reviewed at least once a year and whenever we launch a new product, country or channel.
Each customer is given a risk rating (low, standard or high) that takes into account, among other factors:
The risk rating determines the depth of checks, the limits applied, how often the relationship is reviewed and the level of approval required.
No business can go live before its verification is complete. Depending on the country and the activity, we collect and verify in particular:
We may ask for any additional document, a video verification or a signed declaration. Information must be accurate and kept up to date; any material change (directors, shareholders, activity, address) must be reported to us within thirty days.
Enhanced due diligence applies to higher-risk relationships, in particular:
Enhanced due diligence may include evidence of source of funds and source of wealth, additional checks on directors and shareholders, lower limits, more frequent monitoring and prior approval by the Compliance Officer.
Monerails is committed to not providing any service, directly or indirectly, to or for the benefit of any person, entity or vessel subject to sanctions. We screen our customers, their directors and beneficial owners, and payout recipients against the following lists:
Screening takes place at onboarding, whenever lists are updated and on relevant transactions. A potential match blocks the transaction until it has been reviewed. A confirmed match leads to the relationship being declined or suspended, transactions being frozen where the law requires it, and the competent authorities or partners being informed.
We do not accept relationships with persons resident, established or operating in a country or territory subject to comprehensive sanctions, or transactions designed to evade sanctions.
We monitor activity throughout the relationship to detect transactions that are unusual, inconsistent with the customer’s profile or potentially suspicious. Our monitoring includes:
We may at any time ask for supporting evidence for a transaction (invoice, contract, source of funds) and hold the transaction in the meantime.
Any suspicious transaction or situation is reviewed by the Compliance Officer, who documents the decision. Where there are reasonable grounds for suspicion, Monerails promptly informs the regulated partner institutions concerned and, where the law provides for it, the competent authorities, including financial intelligence units.
We may suspend a transaction, freeze a card, block a payout or restrict an account while the review is under way.
No one working on Monerails may tell a customer, or any third party, that a review is under way, that a report has been or will be made, or that an investigation is being considered. As a result, we may decline or suspend a service without giving a reason.
We keep verification documents and information, relevant correspondence and transaction records for at least five years after the end of the business relationship or after the transaction, in line with FATF Recommendation 11, and for up to ten years where applicable local regulation requires it.
These records are stored securely with restricted access, and may be provided to competent authorities as permitted by law. How we process personal data is described in our Privacy Policy.
Relevant staff receive AML/CTF and sanctions training when they join and at least once a year, tailored to their role. Training covers the regulations, red flags specific to mobile money payments and cards, and internal reporting procedures.
The effectiveness of the programme is tested on an ongoing basis and subject to an independent review, internal or external, at a frequency proportionate to the risks. Findings are tracked in an action plan followed by management.
This policy is reviewed at least once a year, and whenever there is a material change in regulation, in our products or in our countries.
Monerails and its regulated partners may at any time, and without giving reasons where the law prohibits it:
Monerails cooperates with the competent judicial, administrative and supervisory authorities, and with its regulated partners, in accordance with applicable law. We respond to lawful requests for information within the required time.
For any question about this policy, or to report suspicious activity linked to Monerails: compliance@monerails.com. Post: Rollo Technologies Inc., 1111B S Governors Ave, Suite 59264, Dover, DE 19904, United States.