The operation of the GoPay Payment System is governed by this AML Policy together with the Terms nad Conditions and other policies. The AML Policy governs how we prevent the legalisation of proceeds from criminal activity and financing of terrorism.
Definitions used in thisAMLPolicyhavethemeaningdefined in theTermsandConditionsunlessexpresslystatedotherwiseherein.
Why We Identify
We are a financial institution pursuant to Czech Act No. 253/2008 Coll., which makes provision with respect to certain measures against the legalisation of proceeds from criminal activity and financing of terrorism, as amended (hereinafter referred to as the “Act”).
In accordancewiththeActwetakemeasuresagainstthelegalisationofproceedsfromcriminalactivityandfinancingofterrorism. Wefulfilobligationsstipulated by legalregulations in thisfieldsoas to preventthemisuseofthefinancialsystem for thelegalisationofproceedsfromcriminalactivityandfinancingofterrorismandsoas to establishconditions for detecting such conduct.
The Actobligesus to meetobligations in relation to Clients. Theaboveobligationsinclude in particularperformingidentificationofClients (S. 7 oftheAct) andperformingduediligenceofClients in casesstipulated by theAct (S. 9 oftheAct).
When We Identify
We perform identification of a Client if a transaction is suspicious or if a Client makes Electronic Money payments and Redemption of Electronic Money in an amount exceeding EUR 2,500 or makes a Redemption of Electronic Money in an amount of EUR 1,000 and higher during one calendar year. We also perform identification of a Client in other cases if stipulated by the Act.
We alwaysrequirethat a Clientperformtheiridentificationorsendtheiridentification data when a GoPayAccountisactivatedandwhen a Clienttransfers to a higherGoPayAccountidentificationlevel. Thescopeofrequiredidentification data isdefined by theselectedGoPayAccountlevel.
How We Identify
Identification is performed in one of the following ways:
Withthephysical presence of a Clientwhoisbeingidentified; werecordandverifytheClient’sidentification data fromtheidentificationcard. AtthesametimeweverifythattheClient’sappearancecorresponds to thephoto on the identity card;
Without the physical presence of a Client who is being identified on condition that the first payment is made through a bank account maintained in the Client’s name and that the Client at the same time submits a copy of their identification documents in electronic form;
Without the physical presence of a Client who is being identified if the Client submits a public deed on identification.
How We Prevent Fraud
We apply control system and anti-fraud management system togehter with internal guidelines the aim of which is to prevent the legalisation of proceeds from criminal activity and financing of terrorism. In accordance with that we use risk management whose aim is to prevent the risk of having the GoPay Payment System misused for fraudulent transactions or other illegal activities. The internal guidelines are submitted for inspection to the Ministry of Finance of the Czech Republic.
Before eachtransactionismade, wecarryoutananalytical risk assessmentbased on alreadyknowninformationabout a Client, informationsubmitted by a Clientorinformationprovided by thirdparties. Wereservetheright to refuse to make such transactionuponassessmentofthedegreeofpotential risk.
We performautomatedassessmentofsuspiciousfinancialflowsandregularly report to pertinentpersonsandduediligencedivisionswithinourcompanyaswellas to publicauthorities such asthe Ministry of Finance ofthe Czech Republic.
We regularly analyse threatsof new risks to whichweadapttheset-upofthewholesystemanditsbehaviour.
We mayask a Client to identifythemselvesagainsoas to verifythecorrectnessoftheoriginallyperformedidentification.
We regularlycheckwhethertheactivitiesandrangeofproductsoffered on thewebsitethroughwhich a Clientoffersoreffectsthesaleofgoodsoroffersorprovidesservicescorresponds to theactivityandrangeofproductsdeclared by theClient. Weregularlycarryout test purchasesofgoodsandservices in order to verifywhether a givenClientbehaves duly and in accordancewiththeContract.
We are entitled to unilaterally amend the AML Policy in accordance with the rules and terms and conditions laid down in this Article. A Client agrees with the above entitlement.
If weamendtheAMLPolicy, we are obliged to notifytheClientofthischange in advance by e-mailcontaining a link to the new AMLPolicyfromwhere a Clientmayprintitor download it in electronicform.
The AMLPolicyisissued in electronicformandisavailableatGOPAY’swebsite.