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LEGAL

AML/CFT Policy

Anti-Money Laundering & Counter-Terrorism Financing Policy

Last updated: July 28, 2026

Effective: August 27, 2026 for merchants with an existing account on July 28, 2026. The changes in this version apply immediately to accounts created on or after July 28, 2026.

Our Role as a Technology Provider

PD Cash operates as a payment orchestration SaaS platform — a technology provider that routes transactions to licensed channel partners and payment processors. We do not directly process payments, hold customer funds, or act as a financial institution. Statutory Know Your Customer (KYC) and Know Your Business (KYB) obligations for merchants sit with the licensed channel partners, payment gateways, and acquiring banks that onboard and verify merchants under their own compliance programmes. PD Cash nevertheless carries out its own onboarding and due-diligence checks, described in Section 5. Those checks are additional to the statutory obligations of the licensed entities, not a substitute for them.

1. Introduction & Scope

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy outlines PD Cash's commitment to preventing the use of our payment orchestration platform for money laundering, terrorist financing, or other financial crime.

As a technology provider offering SaaS-based payment routing software, our role in the payment ecosystem differs from that of a traditional financial institution or payment processor. This Policy reflects our position as a technology intermediary while setting out the controls we operate in our own right.

2. Our Position in the Payment Chain

Understanding our role is essential to understanding our AML/CFT obligations:

  • PD Cash provides the technology layer that routes payment transactions between merchants and payment providers. We are a SaaS technology provider.
  • Channel Partners and payment gateway providers are the regulated entities that process actual payments. They perform statutory KYC on the merchants they onboard, according to their own regulatory requirements.
  • Acquiring banks provide merchant accounts and bear the primary regulatory responsibility for merchant due diligence and transaction monitoring.
  • Merchants are the businesses using our platform to route their payment transactions. Their statutory KYC verification is completed by their channel partner or acquiring bank, in addition to the onboarding checks PD Cash performs under Section 5.

Because we are a technology provider and do not directly process payments, custody funds, or establish banking relationships with end customers, the statutory KYC requirements applicable to financial institutions and payment processors do not directly apply to our SaaS platform. Statutory responsibility for merchant onboarding KYC lies with the licensed entities that have the direct contractual and regulatory relationship with the merchant. PD Cash nonetheless applies its own onboarding and ongoing due-diligence checks under Section 5, which are additional to, and do not replace, those obligations.

Regulatory liability for payment processing, anti-money laundering enforcement, statutory customer due diligence, transaction monitoring for regulatory reporting purposes, and Suspicious Activity Report (SAR) filing rests with the licensed channel partners, payment gateway providers, and acquiring banks. PD Cash bears no liability for regulatory non-compliance, fines, or penalties arising from the payment processing activities conducted by those entities.

3. Our AML/CFT Commitments

Although we are not a regulated financial institution, PD Cash is committed to:

  • Preventing the use of our platform for money laundering or terrorist financing purposes
  • Cooperating with law enforcement and regulatory authorities when required
  • Implementing reasonable measures to detect suspicious activity within our platform
  • Maintaining records of transactions routed through our system
  • Refusing service to individuals or entities on international sanctions lists
  • Training our team on AML/CFT awareness and red flag indicators

4. Risk-Based Approach

We adopt a risk-based approach to AML/CFT that is proportionate to our role as a technology provider:

4.1 Platform-Level Controls

  • Transaction monitoring for unusual patterns (velocity, amounts, frequency)
  • Automated flagging of transactions exceeding defined thresholds
  • Monitoring for rapid account creation patterns
  • Detection of transaction structuring (smurfing) attempts
  • IP-based risk scoring and geographic analysis

4.2 Merchant Screening

  • Review of merchant business descriptions and website content
  • Screening against publicly available sanctions lists (OFAC, EU, UN)
  • Monitoring merchant chargeback ratios and dispute patterns
  • Assessment of business category risk levels
  • Investigation of reported suspicious activity

4.3 Reliance on Licensed Partners & Liability Allocation

We rely on the licensed channel partners and payment gateway providers we integrate with to fulfil the statutory compliance obligations that attach to the regulated activity. The following responsibilities and associated liabilities rest with those entities:

  • Performing statutory KYC and KYB on the merchants they onboard — liability for inadequate statutory verification rests with the licensed entity
  • Conducting regulatory customer due diligence, enhanced due diligence, and transaction monitoring — the licensed entity bears liability for its own compliance failures
  • Filing Suspicious Activity Reports (SARs) with the relevant authorities — the licensed entity is solely liable for reporting failures
  • Complying with their jurisdictional AML/CFT regulatory requirements — regulatory fines and penalties are the responsibility of the licensed entity
  • Maintaining appropriate licensing for payment processing activities — the licensed entity bears liability for operating without proper authorization
  • Ensuring sanctions screening at the transaction and settlement level — the licensed entity is liable for processing sanctioned transactions

PD Cash shall not be held liable for AML/CFT compliance failures, regulatory penalties, or enforcement actions arising from the payment processing activities of connected licensed partners. This allocation of statutory responsibility does not reduce the checks PD Cash performs at its own layer under Section 5.

5. Merchant Onboarding & Due Diligence

PD Cash is not a bank, money transmitter, or money services business, and does not custody merchant funds. It nevertheless operates its own onboarding and due-diligence process before an account may route live transactions, and reviews accounts on an ongoing basis afterwards. This process is additional to, and does not replace, the statutory obligations of the licensed channel partners.

5.1 What PD Cash does at onboarding

  • Verifies the applicant's identity and, for a company, the legal entity, its registration details, and the individuals who own or control it
  • Reviews the business model, website, product and service descriptions, checkout flow, and published terms
  • Screens the applicant, its principals, and connected entities against the OFAC, EU, and UN consolidated sanctions lists
  • Collects licensing evidence for regulated verticals, for every jurisdiction served — including gaming licences, content distribution or rights documentation, and any sector-specific authorisation
  • Assesses expected volume, average ticket size, refund and dispute history, operating regions, and geo-blocking arrangements
  • Assigns a risk tier that determines monitoring intensity, velocity limits, deposit requirements, and review frequency
  • Reserves the right to decline an application, approve it subject to conditions, or request further information at any point, without being obliged to give reasons

5.2 What the licensed channel partner does

  • Statutory KYC and KYB under its own regulatory obligations
  • Underwriting, and the decision to open, limit, suspend, or close a merchant account
  • Transaction monitoring for regulatory reporting purposes
  • Filing Suspicious Activity Reports and any other regulatory reporting
  • Custody of funds and settlement to the merchant

5.3 Ongoing due diligence

  • Periodic re-screening of merchants and principals against sanctions lists
  • Re-verification when ownership, business model, product mix, or operating regions change
  • Enhanced review where volume, ticket size, dispute ratio, or geography moves materially away from what was declared at onboarding
  • Re-verification of licences and rights documentation before expiry, for regulated and restricted verticals
  • Review triggered by a partner request, a law-enforcement inquiry, or a credible third-party report

A merchant that does not provide requested information within a reasonable period may have its account restricted, suspended, or closed. Merchants connecting their own API keys (BYOK) remain subject to these checks, in addition to any verification already completed by their own payment provider.

6. Suspicious Activity Detection

We monitor for and investigate the following red flags:

  • Unusual transaction volumes inconsistent with the merchant's stated business
  • Rapid increase in transaction values without clear business justification
  • Patterns of transactions just below reporting thresholds
  • Multiple accounts linked to the same individual or entity
  • Transactions involving high-risk jurisdictions
  • Excessive chargebacks or refund patterns suggesting fraudulent activity
  • Attempts to use the platform for transactions not matching the stated business type
  • Transactions with no apparent economic purpose

7. Sanctions Compliance

PD Cash is committed to complying with applicable economic sanctions:

  • We screen against OFAC (U.S. Office of Foreign Assets Control) sanctions lists
  • We screen against EU and UN consolidated sanctions lists
  • We do not knowingly provide services to sanctioned individuals, entities, or countries
  • We block or restrict access from comprehensively sanctioned jurisdictions
  • Positive matches result in immediate account suspension and investigation

8. Record Keeping

We maintain records of:

  • All transactions routed through our platform (amounts, dates, parties, providers)
  • Account registration and onboarding due-diligence information
  • Suspicious activity investigations and outcomes
  • Communications related to compliance inquiries
  • Platform access logs and security events

Records are retained for the period required by applicable regulation, and for a minimum of 5 years after account closure or the transaction date. Retention periods for each record type are set out in the Privacy Policy.

9. Cooperation with Authorities

PD Cash will:

  • Respond to valid legal requests (subpoenas, court orders, regulatory inquiries)
  • Cooperate with law enforcement investigations
  • Report suspected criminal activity to appropriate authorities
  • Freeze or restrict accounts when required by law
  • Provide transaction records and account information as legally required

10. Account Suspension & Termination

We reserve the right to immediately suspend or terminate accounts when:

  • Suspicious activity is detected that suggests money laundering or terrorist financing
  • A merchant is found on a sanctions list
  • Law enforcement requests account restriction
  • Transaction patterns indicate potential financial crime
  • A merchant is found to be operating a prohibited business type, or a restricted category without approval
  • Requested due-diligence information is not provided within a reasonable period

11. Training & Awareness

Our team receives training on:

  • Recognition of money laundering and terrorist financing indicators
  • Sanctions compliance obligations
  • Suspicious activity identification and escalation procedures
  • Platform-specific risk indicators and patterns
  • Updates to relevant regulations and industry best practices

12. Policy Review

This AML/CFT Policy is reviewed and updated periodically to reflect changes in regulation, industry standards, and our operational practices. We are committed to maintaining compliance standards appropriate to our role as a technology provider in the payment ecosystem.

13. Contact Us

For questions about this AML/CFT Policy or to report suspicious activity, please contact us:

  • Contact form: pd.cash/contact#contact-form
  • Website: pd.cash