AML policy

General

1. 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.
2. Definitions used in this AML Policy have the meaning defined in the Terms and Conditions unless expressly stated otherwise herein.

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   Why We Identify

3. 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”).
4. In accordance with the Act we take measures against the legalisation of proceeds from criminal activity and financing of terrorism. We fulfil obligations stipulated by legal regulations in this field so as to prevent the misuse of the financial system for the legalisation of proceeds from criminal activity and financing of terrorism and so as to establish conditions for detecting such conduct.
5. The Act obliges us to meet obligations in relation to Clients. The above obligations include in particular performing identification of Clients (S. 7 of the Act) and performing due diligence of Clients in cases stipulated by the Act (S. 9 of the Act).

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   When We Identify

6. 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.
7. We always require that a Client perform their identification or send their identification data when a GoPay Account is activated and when a Client transfers to a higher GoPay Account identification level. The scope of required identification data is defined by the selected GoPay Account level.

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   How We Identify

8. Identification is performed in one of the following ways:
   1. With the physical presence of a Client who is being identified; we record and verify the Client’s identification data from the identification card. At the same time we verify that the Client’s appearance corresponds to the photo on the identity card;
   2. 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;
   3. Without the physical presence of a Client who is being identified if the Client submits a public deed on identification.

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   How We Prevent Fraud

9. 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.
10. Before each transaction is made, we carry out an analytical risk assessment based on already known information about a Client, information submitted by a Client or information provided by third parties. We reserve the right to refuse to make such transaction upon assessment of the degree of potential risk.
11. We perform automated assessment of suspicious financial flows and regularly report to pertinent persons and due diligence divisions within our company as well as to public authorities such as the Ministry of Finance of the Czech Republic.
12. We regularly analyse threats of new risks to which we adapt the set-up of the whole system and its behaviour.
13. We may ask a Client to identify themselves again so as to verify the correctness of the originally performed identification.
14. We regularly check whether the activities and range of products offered on the website through which a Client offers or effects the sale of goods or offers or provides services corresponds to the activity and range of products declared by the Client. We regularly carry out test purchases of goods and services in order to verify whether a given Client behaves duly and in accordance with the Contract.

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    Final Provisions

15. 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.
16. If we amend the AML Policy, we are obliged to notify the Client of this change in advance by e-mail containing a link to the new AML Policy from where a Client may print it or download it in electronic form.
17. The AML Policy is issued in electronic form and is available at GOPAY’s website.
18. The AML Policy comes into effect as of 10/1/2014.