Compliance

ANTI-MONEY LAUDERING & COMBATING TERRORIST FINANCING POLICY (AML/CFT)

WORLDBRIDGE-PAYMENT SERVICES S.A.” with the distinctive title “PayLink” (hereinafter “PayLink”), an authorized Greek Payment Institution, licensed by the Bank of Greece, offers payment services in cooperation with Western Union in Greece and worldwide.

In accordance with applicable legislation WorldBridge has implemented certain practices, procedures and a written anti-money laundering/combating the financing of terrorism policy (hereinafter “AML/CFT”), necessary to monitor and prevent potential use of its services for money laundering and the financing of terrorism and other criminal offences.

WorldBridge’s Board of Directors has approved this AML/CFT (anti money laundering Policy and it applies to WorldBridge’s Central offices, branches and its entire network of Associates. The AML/CFT Policy is adapted to the nature of WorldBridge’s business and is assessed on a periodical basis.

The Board of Directors appoints an AML/CFT and Compliance Officer and its Deputy in case of absence or impediment, responsible for monitoring, assessing the AML/CFT Policy and ensuring its implementation.

The AML/CFT Officer also reports unusual/suspicious transactions to the competent Authorities, keeps records of the alerts produced by the system, the reports and all customers’ identification data and transactions.

WorldBridge has designed and operates a centralized IT system designed to implement and materialize its AML/CFT Policy. Moreover, the IT system controls all transactions on the basis of the international typology of suspicious transactions as in force, adjusted to its types of transactions, issues alerts of such unusual or suspicious transactions on the basis of the aforementioned criteria, controls on a real time basis clients and transactions on the basis of list of persons who have committed criminal offences, prepared by the competent police and judicial Authorities and also controls on a real time basis, in cooperation with Western Union, clients and transactions on the basis of lists of persons subject to sanctions under the EU Regulations and Resolutions of the UN Security Council and O.F.A.C. (Treasury’s Office of Foreign Assets Control), as well as a list of persons as notified to Western Union by third countries outside the EU and the USA.

Customer Acceptance Policy. Most customers are walk-in customers who may either be residents or not and need to use the service for an emergency. Therefore, WorldBridge has implemented the policy to control and verify each customer’s identification prior to the commencement of a transaction (KYC principle). For goCASH transactions and up until a certain amount a different procedure is applied. Customers who are found on lists of persons subject to sanctions under the EU Regulations and Resolutions of the UN Security Council and O.F.A.C. (Treasury’s Office of Foreign Assets Control), as well as a list of persons as notified to Western Union by third countries outside the EU and the USA are not allowed to use the service. Customers who do not provide identification or do not cooperate are not allowed to use the service. Customers whose transactions have repeatedly been reported are prohibited from using the service anymore.