Anti-Money Laundering Policy

1. Policy Statement

Squid Pay Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our commitment to preventing the use of our services for money laundering, terrorist financing, or other illicit purposes.

As a registered Money Services Business in the Cayman Islands, we operate in full compliance with the Proceeds of Crime Act (2020 Revision), the Anti-Money Laundering Regulations (2020 Revision), and guidance issued by the Cayman Islands Monetary Authority (CIMA).

2. Regulatory Framework

Our AML program is designed to comply with:

• Proceeds of Crime Act (2020 Revision)
• Anti-Money Laundering Regulations (2020 Revision)
• Terrorism Act (2018 Revision)
• CIMA Guidance Notes on the Prevention and Detection of Money Laundering
• Financial Action Task Force (FATF) Recommendations

3. Know Your Customer (KYC)

We conduct thorough Customer Due Diligence (CDD) on all merchants before establishing a business relationship. Our KYC procedures include:

• Verification of identity using government-issued documents
• Verification of business registration and legitimacy
• Assessment of the nature and purpose of the business relationship
• Screening against sanctions lists and PEP databases
• Ongoing monitoring of merchant activity and transactions

4. Enhanced Due Diligence

We apply Enhanced Due Diligence (EDD) measures for higher-risk merchants, including:

• Politically Exposed Persons (PEPs) and their associates
• Merchants from higher-risk jurisdictions
• Complex or unusual business structures
• Businesses operating in higher-risk industries
• Merchants with unusual transaction patterns

5. Transaction Monitoring

We employ robust transaction monitoring systems to detect suspicious activity, including:

• Automated monitoring for unusual transaction patterns
• Velocity checks and threshold monitoring
• Geographic anomaly detection
• Manual review of flagged transactions
• Regular review of merchant account activity

6. Suspicious Activity Reporting

We are obligated to report suspicious activities to the Financial Reporting Authority (FRA) of the Cayman Islands. All staff are trained to identify and escalate potential suspicious activity. We maintain strict confidentiality regarding any reports filed and do not "tip off" subjects of reports.

7. Record Keeping

In accordance with regulatory requirements, we maintain comprehensive records of all customer identification documents, transaction records, and internal reports for a minimum of five (5) years following the termination of the business relationship.

8. Staff Training

All employees receive regular training on AML/CTF requirements, including recognizing suspicious activity, understanding regulatory obligations, and following internal reporting procedures. Training is provided upon hiring and refreshed annually.

9. Compliance Officer

We have appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing our AML program, receiving internal suspicious activity reports, and liaising with regulatory authorities. A Deputy MLRO is also appointed to ensure continuity.

10. Contact

For questions about our AML policy or to report concerns: