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Anti-money laundering rules (AML rules) – effective from 1 March 2018 to 1 April 2021

Basic information

  1. Together with the Terms and Conditions and other rules, these AML rules govern the operation of the GoPay Payment System. The AML rules set out how we prevent the legalisation of the proceeds of crime and the financing of terrorism.

  2. The terms used in these AML rules have the meaning defined in the Terms and Conditions, unless expressly stated otherwise here.


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Why we carry out identification

  1. We are a financial institution under Czech Act No. 253/2008 Coll., on certain measures against the legalisation of the proceeds of crime and the financing of terrorism, as amended (hereinafter the “Act”).

  2. In accordance with the Act we take measures against the legalisation of the proceeds of crime and the financing of terrorism. We fulfil the obligations laid down by legislation in this area in order to prevent the financial system being misused for the legalisation of the proceeds of crime and the financing of terrorism, and in order to create conditions for detecting such conduct.

  3. The Act requires us to fulfil obligations in relation to Clients. These obligations include in particular carrying out identification of Clients (Section 7 of the Act) and, in the cases laid down by the Act, also carrying out checks on Clients (Section 9 of the Act).


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When we carry out identification

  1. We will carry out your identification at the latest when, within one calendar year, you make payments in Electronic Money in an amount exceeding EUR 250, or the amount held in your GoPay account exceeds EUR 250, or you carry out a Redemption of Electronic Money in an amount of EUR 100 or more. We will also carry out identification in other cases where this obligation is imposed by the Act.

  2. We always require your identification details to be sent, or your identification to be carried out, when a GoPay account is activated and when moving to a higher level of GoPay account. The range of identification details required is defined by the level of GoPay account selected.


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How we carry out identification

  1. We carry out identification in one of the following ways:

    1. in your physical presence, where we record the identification details and verify them against an identity document. At the same time we verify that your appearance matches the image in the identity document.

    2. without your physical presence, provided that the first payment is made through a bank account held in your name and that you also submit copies of your identity documents electronically.

    3. without your physical presence, if you submit a public deed of identification.


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How we prevent fraudulent transactions

  1. We apply a management and control system and a system of internal policies aimed at preventing the legalisation of the proceeds of crime and the financing of terrorism. Accordingly, we use systemic approaches aimed at preventing the risk of the GoPay Payment System being misused for fraudulent transactions or other illegal activities. The system of internal policies is submitted for review to the Ministry of Finance of the Czech Republic.

  2. Before every transaction is carried out we perform an analytical risk assessment on the basis of information about you or information provided by third parties. On the basis of the assessment of the level of potential risk, we reserve the right to refuse to carry out such a transaction.

  3. We assess suspicious financial flows automatically and carry out regular reporting to the relevant persons and control units within our company and also to public authorities such as the Ministry of Finance of the Czech Republic.

  4. We regularly analyse the threats of new risks and adapt the settings of the whole system and its behaviour accordingly.

  5. We may ask you to repeat the identification in order to verify the correctness of the identification originally carried out.

  6. We regularly check whether the activities and the range of goods presented on the websites through which you offer or sell goods, or offer or provide your services, correspond to the activities and range you have declared to us.

  7. We are entitled to make test purchases (“Mystery shopping”) through the GoPay Payment Gateway on your sales portal (e-shop); after carrying out the transaction we will inform you of its purpose and ask for it to be cancelled and the funds returned. The purpose of test purchases is to verify that transactions are carried out correctly, and we are not liable for any damage or costs incurred by you as a result of a particular transaction being carried out.


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Final provisions

  1. We are entitled to amend these AML rules unilaterally according to the rules and conditions set out in this article. You agree to this entitlement.

  2. If we amend the AML rules, we are obliged to notify you of the change in advance by an e-mail message containing a link to the new AML rules, from where you can print them or save them in electronic form.

  3. The AML rules are issued in electronic form and are available on the GOPAY website.

  4. The AML rules take effect on 1 March 2018.

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