AML Policy

UAB UniPayment maintains a risk-based Anti-Money Laundering and Counter-Terrorist Financing framework designed to prevent the misuse of its payment-related services for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity.

UAB UniPayment’s AML/CFT controls are designed to support compliance with applicable Lithuanian and European Union anti-money laundering and counter-terrorist financing requirements. UAB UniPayment provides payment-related services within its permitted scope as an EMI agent and does not provide crypto-asset services.

UAB UniPayment applies customer due diligence measures before providing services. These measures may include collecting and verifying customer identification information, company registration details, ownership and control information, business activity, expected transaction profile, and source of funds or source of wealth where required.

Enhanced due diligence may be applied where a customer, transaction, jurisdiction, industry, ownership structure, or activity pattern presents higher financial crime risk. UAB UniPayment may refuse onboarding, restrict services, request additional information, suspend activity, or terminate a relationship where required information is not provided or where the risk is outside its risk appetite.

UAB UniPayment conducts screening against applicable sanctions lists, politically exposed person databases, adverse media sources, and other relevant risk indicators, as appropriate to the customer, product, and jurisdiction.

Customer activity and transactions are monitored on an ongoing basis to identify unusual, inconsistent, or potentially suspicious activity.

Potentially suspicious activity is escalated to UAB UniPayment’s compliance function for review. Where further escalation or reporting is required, the matter is handled in accordance with applicable legal and regulatory requirements.

UAB UniPayment maintains compliance oversight through a designated compliance officer and MLRO function, internal escalation procedures, staff guidance, and periodic review of its AML/CFT controls.

UAB UniPayment retains customer due diligence records, transaction records, compliance reviews, and supporting documentation for the periods required by applicable law and internal policy.

Records are maintained to support auditability, regulatory inquiries, and internal compliance review.

This policy provides an overview of UAB UniPayment’s AML/CFT control framework. Detailed internal procedures, monitoring rules, escalation workflows, and risk assessment methodologies are maintained separately and are not published for security and operational reasons.

UAB UniPayment does not provide crypto-asset services. Accordingly, Travel Rule obligations relating to transfers of crypto-assets are not applicable to the fiat Virtual IBAN top-up services provided by UAB UniPayment.

Last updated: July 2026