Legal

AML & Financial Crime

Preventing financial crime is built into how Novapayx operates. This summary explains our approach; detailed internal policies and thresholds are maintained by our compliance function and are not published.

Effective 1 July 2026 ยท Version 1.0

Our commitment

Novapayx and its regulated entities and partners are committed to preventing money laundering, terrorist financing, proliferation financing, sanctions evasion, and fraud. Our programme is designed to meet the AML/CFT requirements applicable in each region โ€” including the EU anti-money-laundering framework and the Markets in Crypto-Assets Regulation (MiCA) in the EEA, the U.S. Bank Secrecy Act and FinCEN requirements in the United States, and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC requirements in Canada.

Risk-based approach

We assess money-laundering and terrorist-financing risk across customers, products, jurisdictions, channels, and transactions, and apply controls proportionate to that risk. Higher-risk relationships are subject to enhanced measures and senior sign-off.

Identity verification (KYC & KYB)

Individuals complete Know-Your-Customer (KYC) checks and businesses complete Know-Your-Business (KYB) checks before sensitive capabilities are enabled. Depending on risk and jurisdiction this can include government-issued identity verification, proof of address, verification of beneficial owners and controllers for businesses, and, where warranted, source-of-funds and source-of-wealth evidence. Enhanced due diligence (EDD) applies to higher-risk customers, including politically exposed persons (PEPs).

Ongoing monitoring

Customer activity is monitored on a risk-based basis throughout the relationship, using transaction and behavioural monitoring to detect unusual or suspicious patterns, structuring, and fraud. We may request additional information or documentation, and may pause, review, or restrict activity where necessary.

Blockchain & on-chain analytics

For digital-asset activity, we use blockchain analytics to assess the provenance and risk of crypto-asset transactions and counterparties, and to identify exposure to illicit sources, sanctioned addresses, or high-risk services.

Sanctions, PEP & adverse-media screening

Customers and, where applicable, counterparties are screened against sanctions lists (such as OFAC, EU, UN, and other applicable regimes), PEP data, and adverse media, both at onboarding and on an ongoing basis. We do not provide services to sanctioned persons or in comprehensively sanctioned or restricted jurisdictions.

Travel Rule

Where applicable, we comply with "Travel Rule" obligations for crypto-asset and fund transfers, collecting and transmitting required originator and beneficiary information with our regulated partners.

Suspicious activity reporting

Where we identify suspicious activity, we report it to the relevant financial intelligence unit or authority and cooperate with regulators and law enforcement. We may be legally prohibited from informing you that a report has been made, and may be required to suspend or decline activity.

Governance & oversight

Our programme is overseen by a designated compliance function, including a Money Laundering Reporting Officer (or equivalent) for the relevant entity, with board/senior-management accountability and periodic independent review and testing.

Training & awareness

Relevant staff receive AML/CFT training appropriate to their role, refreshed on a regular basis and when obligations change.

Record-keeping

We retain customer due-diligence records, transaction records, and reports for the periods required by applicable law.

What we ask of you

Provide accurate, current information, respond to verification and compliance requests, and use Novapayx only for lawful purposes in line with our Acceptable Use Policy. Misuse may result in restriction, suspension, or closure of your account.

Contact

Compliance enquiries: compliance@novapayx.com, or contact us.