Amajova Anti-Money Laundering (AML) Policy

1. Introduction

Amajova is committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. While Amajova is not a Money Services Business (MSB) or a Payment Service Provider (PSP), we implement strict AML measures in collaboration with third-party PSPs and KYC provider Persona (withpersona.com) to prevent illicit activities such as money laundering, fraud, and terrorist financing.

This policy outlines Amajova’s risk-based approach, fraud prevention measures, and compliance practices in alignment with:

EU Payment Services Directive 2 (PSD2) – Article 3(b)

UK Financial Conduct Authority (FCA) AML Guidelines

US Financial Crimes Enforcement Network (FinCEN) Regulations

Applicable global AML and CTF laws

2. Identity Verification (KYC) & Customer Due Diligence (CDD)

To ensure a secure platform, Amajova enforces Know Your Customer (KYC) and Customer Due Diligence (CDD) verification for all users.

KYC Process

Amajova partners with Persona (withpersona.com) to conduct KYC verification, which includes:

✅ Photo ID authentication & biometric verification before transactions are approved.

✅ Name matching between the verified ID and the payment method to prevent fraudulent transactions.

✅ Additional screening for high-risk users, including:

🔹 Enhanced Due Diligence (EDD) for large transactions.

🔹 Verification of Ultimate Beneficial Ownership (UBO) for businesses using Amajova.

🔹 Amajova does not store or manage KYC documents. Persona securely stores all identity verification data in compliance with GDPR and global data protection laws.

3. Payment Verification & Fraud Prevention

To prevent payment fraud and unauthorized transactions, Amajova requires clients to complete payment verification before funds are processed.

✅ Clients must verify payments by submitting:

🔹 A screenshot of the payment notification, showing Amajova as the recipient.

🔹 A signed declaration confirming that:

       🔹 The payment was made by them.

       🔹The payment matches the name on their verified ID.

       🔹They will not file fraudulent chargebacks.

🔹A redacted image of the payment card used, showing only the last four digits for security.

✅ Payment Matching Requirement

🔹The payment method used must match the name on the client’s KYC-verified ID.

🔹 Any discrepancies may require additional verification before funds are processed.

✅ Delayed Payment Release for Fraud Prevention

🔹 Freelancer funds are only released after the client confirms project completion.

🔹 If a client does not confirm within a set timeframe, Amajova may intervene based on the Dispute Resolution Policy.

4. Suspicious Activity Monitoring & Reporting

Amajova actively monitors transactions and user behavior to detect suspicious activity, including:

🔹 Unusual transaction patterns, such as multiple rapid withdrawals.

🔹 Users logging in from high-risk locations or using multiple identities.

🔹 Excessive refund requests or chargeback abuse.

🚨 How Suspicious Activity is Handled:

🔹Amajova flags and escalates suspicious transactions to its third-party PSPs for further review.

🔹If necessary, PSPs file Suspicious Activity Reports (SARs) with financial regulators.

🔹Users involved in fraudulent activity may be banned or reported to authorities.

5. Sanctions Compliance & Restricted Jurisdictions

Amajova complies with global sanctions programs, including:

✅ OFAC (U.S.), UN, EU, and UK Sanctions Lists.

✅ PSPs screen against sanctioned individuals and entities before processing payments.

✅ Restricted Countries:

🔹Amajova does not accept users from high-risk jurisdictions, including:

         🔹Afghanistan, Belarus, Cuba, Iran, North Korea, Russia, Syria, and other sanctioned regions.

🔹Users found circumventing these restrictions may be permanently banned.

6. Data Protection & GDPR Compliance

Amajova ensures that all KYC and payment verification data is handled in compliance with:

✅ General Data Protection Regulation (GDPR)

✅ UK Data Protection Act (DPA) 2018

✅ Other applicable privacy laws

🔹 Amajova does not store or retain KYC data—Persona securely manages all identity verification records.

🔹 Amajova does not store payment card details—these are handled securely by third-party PSPs.

🔹 Users may request data deletion in compliance with GDPR regulations.

7. Ongoing AML Compliance & Audits

Amajova continuously enhances its AML framework to meet evolving regulatory requirements.

📌 Internal AML reviews and policy updates occur annually.

📌 Employees receive regular AML compliance training.

📌 Independent audits may be conducted to assess AML policy effectiveness.

8. Enforcement & Policy Violations

Amajova enforces a zero-tolerance policy for money laundering, fraud, and financial crime.

🔹 Any user found violating this AML policy may face:

🔹Account suspension or termination.

🔹Legal action and law enforcement notification.

🔹Funds being held or forfeited based on the investigation outcome.

📌 For AML-related inquiries, contact our Compliance Team at: [security at amajova.com]