1. OBJECTIVE OF THE AML POLICY

Agent Pay Ltd is fully committed to complying with all applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations. All of our employees and partners adhere to the highest standards of regulatory compliance to minimize the risk that our services could be used to facilitate money laundering, terrorist financing, or any other form of financial crime.

Payment services are provided by Marvli Payment OÜ, an Estonian company incorporated under number 16338540, which is a regulated entity registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB) under registration number M24723823.

Agent Pay Ltd (hereinafter referred to as “Wallixor,” “we,” “us,” or “our”) is a company incorporated under the laws of England and Wales with company number 16507537 and its registered office at 128 City Road, London, United Kingdom, EC1V 2NX.

While Marvli Payment OÜ is the issuer of accounts and provider of payment services, Wallixor acts solely as its agent and technology platform partner.

Marvli Payment OÜ maintains client funds in segregated accounts held with electronic money institutions (EMIs) or licensed banking partners that apply safeguarding mechanisms to protect customer funds in accordance with applicable financial regulations. Consequently, clients’ funds are held separately from the company’s own operational funds. These funds are not covered by deposit protection schemes such as the FSCS, but are safeguarded under the regulatory framework governing EMIs and licensed financial institutions.

We have adopted this AML Policy framework to ensure that all necessary measures are implemented to maintain the integrity and security of our services. This policy has been designed in accordance with Canadian AML legislation, Estonian and UK regulatory standards, and international AML best practices.

2. WHAT IS AML POLICY?

The AML Policy outlines our internal procedures and controls designed to prevent the use of our services for money laundering, terrorist financing, or other illegal activities. It defines our KYC (Know Your Customer) and KYB (Know Your Business) processes, enabling us to identify, verify, and understand our customers to effectively manage risk.

Our AML framework is regularly reviewed and updated to ensure continuous compliance with evolving legislation and best practice guidance.

In cases where potentially suspicious or unusual transactions or customer behavior are detected, enhanced due diligence (EDD) measures are applied. This may include requests for additional documentation such as proof of source of funds (SoF) or source of wealth (SoW).

We maintain an organized and secure record-keeping system for all customer identification data, verification evidence, and related transaction information. All data is retained and processed in accordance with applicable data protection and privacy laws.

3. Scope of the AML Policy

This AML Policy includes, but is not limited to, the following key components::

  • Customer identification and verification prior to establishing a business relationship.
  • Risk-based customer due diligence (CDD), including enhanced due diligence (EDD) for higher-risk clients.
  • Ongoing monitoring of customer transactions and account behavior to identify inconsistencies or suspicious patterns.
  • Procedures for internal and external reporting of suspicious activities to the relevant authorities.
  • Comprehensive AML and compliance training for all relevant employees, agents, and partners.

All AML and compliance operations are conducted under the framework of Marvli Payment OÜ’s AML program, and all applicable procedures follow Marvli Payment OÜ’s internal AML Policy.

Within the customer due diligence process, Wallixor reserves the right to reject customer documents, deny account activation, or terminate a business relationship if suspicious activity, falsified documentation, or non-cooperation is identified.

Marvli Payment OÜ is responsible for reviewing Agent Pay Ltd (Wallixor) clients’ KYC/KYB documentation and ensuring ongoing compliance with applicable AML requirements.

The list of prohibited and restricted countries is available in the Prohibited Countries List.

For the purposes of identity verification, sanctions screening, and ongoing compliance monitoring, Wallixor and Marvli Payment OÜ use the services of Finchecker, a regulated verification and compliance technology provider. Finchecker assists in conducting customer identity verification, screening against global sanctions and watchlists, and performing other due diligence procedures in accordance with international AML standards and regulatory obligations.

4. Response Times

Requests related to AML matters — including verification, compliance reviews, disputes, or other AML-related inquiries — are typically processed within up to seven (7) business days. The same timeframe may apply to account activation or re-verification processes, depending on the complexity of the case and the level of due diligence required.

For any AML purposes, please contact via email: [email protected]