AML Policy

Last updated: March 1, 2026

Anti-Money Laundering & Know Your Customer Policy

DiasporaPay operates under strict AML/KYC compliance frameworks to protect the integrity of the financial system and our users.

1. Our Commitment

DiasporaPay is committed to preventing money laundering, terrorist financing, and other financial crimes. We comply fully with the EU Anti-Money Laundering Directive (AMLD5/AMLD6), Financial Action Task Force (FATF) recommendations, and all applicable national regulations in countries where we operate. Our AML program is overseen by a dedicated Compliance Officer and reviewed annually by external auditors.

2. Customer Due Diligence (CDD)

We apply risk-based Customer Due Diligence to all users: Standard CDD (Tier 1–2): • Verify name, date of birth, and address • Confirm phone number and email • Check against sanctions lists (OFAC, EU, UN) Enhanced Due Diligence (Tier 3 / High-Risk): • Verify government-issued photo ID • Obtain proof of address (utility bill, bank statement) • Collect source of funds declaration for large transfers • Ongoing monitoring of transaction patterns

3. Transaction Monitoring

Our automated systems continuously monitor transactions for suspicious patterns including: • Unusual transaction volumes or frequencies • Structuring (breaking large amounts into smaller transfers to evade limits) • Transfers to or from high-risk jurisdictions • Rapid movement of funds through multiple accounts • Inconsistency between transaction pattern and customer profile Suspicious transactions are reviewed by our compliance team and may be reported to financial intelligence units (FIUs).

4. Sanctions Screening

All users and transactions are screened against: • OFAC Specially Designated Nationals (SDN) list • EU Consolidated Sanctions List • UN Security Council Consolidated List • National sanctions lists of operating countries We do not process transactions involving sanctioned individuals, entities, or countries. Any matches result in account suspension and mandatory reporting.

5. Politically Exposed Persons (PEPs)

Individuals who hold or have held prominent public positions (and their family members or close associates) are classified as Politically Exposed Persons. PEP accounts are subject to Enhanced Due Diligence including senior management approval and enhanced ongoing monitoring. PEP status does not automatically disqualify an individual from using our services.

6. Suspicious Activity Reporting

DiasporaPay files Suspicious Activity Reports (SARs) with relevant FIUs when we have reason to suspect money laundering or terrorist financing. By law, we cannot disclose to users that a SAR has been filed. We cooperate fully with law enforcement investigations and respond to legally valid information requests.

7. Record Keeping

In compliance with AML regulations, we retain: • Customer identification records for 5 years after account closure • Transaction records for 5 years from the date of each transaction • SAR filings and supporting evidence for 5 years • CDD documents and correspondence for 5 years All records are stored securely and available to regulatory authorities upon request.

8. Employee Training

All DiasporaPay employees complete mandatory AML/KYC training upon hire and annually thereafter. Training covers recognition of suspicious activity, regulatory obligations, and internal reporting procedures. Employees are prohibited from tipping off customers about compliance actions.

9. Report Suspicious Activity

If you suspect money laundering or financial crime related to DiasporaPay's services, please report it to our compliance team. Your report will be treated confidentially.

Report Financial Crime

Contact our Compliance Officer at compliance@diasporapay.com

All reports are strictly confidential and protected by whistleblower provisions.