Anti-Money Laundering, Counter-Terrorist Financing and Proliferation Financing Statement
Last updated 11th August 2026
1. Purpose
TWPayz is committed to maintaining effective systems and controls designed to prevent, detect and manage risks relating to money laundering, terrorist financing, proliferation financing, sanctions breaches and other financial crime.
TWPayz is the trading name used by Transactworld Limited and Payment Infosys Limited. References in this Statement to “TWPayz”, “we”, “us” or “our” refer to those entities collectively where appropriate.
Each entity remains separately responsible for complying with the legal, regulatory and supervisory requirements applicable to its business and regulated activities.
This Statement provides a high-level overview of our approach to financial crime prevention. It does not form part of any customer agreement and does not disclose confidential internal controls, risk thresholds, monitoring rules or investigation procedures.
2. Regulatory Framework
Transactworld Limited
Transactworld Limited is incorporated in England and Wales and is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Electronic Money Institution under the Electronic Money Regulations 2011, with Firm Reference Number 900405.
Its financial crime framework is maintained in accordance with applicable UK laws and regulatory requirements, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Sanctions and Anti-Money Laundering Act 2018 and applicable UK sanctions regulations, together with applicable FCA rules and guidance.
Payment Infosys Limited
Payment Infosys Limited is incorporated in Mauritius and is licensed and regulated by the Financial Services Commission of Mauritius (“FSC”) to conduct Payment Intermediary Services under the Financial Services Act 2007.
Its financial crime framework is maintained in accordance with applicable Mauritius laws and regulatory requirements, including the Financial Intelligence and Anti-Money Laundering Act 2002, the Financial Intelligence and Anti-Money Laundering Regulations 2018, the Prevention of Terrorism Act, the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019, and applicable FSC rules and guidance.
3. Risk-Based Approach
Each TWPayz entity applies a risk-based approach to identifying, assessing, managing and mitigating financial crime risks.
In assessing the nature and level of financial crime risk, each TWPayz entity takes into account, as appropriate, relevant risk factors including:
Customer and beneficial ownership profile
Nature and purpose of the business relationship
Products and services
Geographic exposure
Delivery and distribution channels
Expected and actual transaction activity
Other relevant financial crime risk factors
The nature and extent of customer due diligence, ongoing monitoring and other risk-mitigation measures are applied on a risk-sensitive basis, taking into account the level of risk identified and the legal and regulatory requirements applicable to the relevant TWPayz entity.
Risk assessments are subject to periodic review and, where appropriate, are updated to reflect material changes in customer circumstances, business activities, transaction patterns or other relevant financial crime risk factors.
4. Customer Due Diligence
Each TWPayz entity applies customer due diligence measures in accordance with applicable legal and regulatory requirements.
These measures include:
Identifying and verifying customers
Identifying and verifying beneficial owners and relevant controlling persons
Understanding ownership and control structures
Obtaining information on the purpose and intended nature of the business relationship
Understanding the customer’s business activities and expected use of services
Determining whether relevant persons are Politically Exposed Persons (“PEPs”), family members or known close associates
Screening against applicable sanctions restrictions
Obtaining source of funds and/or source of wealth information where required
Where required due diligence cannot be completed satisfactorily, the relevant TWPayz entity may decline to establish or continue the business relationship or take other measures required or permitted by applicable law.
Customer due diligence is not limited to the commencement of a business relationship. Customer information and due diligence records are reviewed and updated, where appropriate, throughout the relationship in accordance with applicable legal and regulatory requirements and the level of risk identified.
5. Enhanced Due Diligence
Enhanced due diligence is applied where required by applicable law or where higher financial crime risk is identified.
Depending on the nature and level of risk identified, Enhanced Due Diligence measures may include obtaining and verifying additional information or supporting documentation in relation to:
The customer’s ownership and control structure, including beneficial ownership
The nature, purpose and scope of the customer’s business activities
The purpose and intended nature of the business relationship
Source of funds and, where appropriate, source of wealth
Geographic exposure and relevant jurisdictional risks
The nature, purpose and expected pattern of transaction activity
Any other information considered necessary to adequately assess and mitigate the identified financial crime risks
Where appropriate or required by applicable law, regulation or the relevant TWPayz entity’s risk-based procedures, Enhanced Due Diligence may also include additional verification measures, enhanced ongoing monitoring and appropriate senior management approval.
6. Ongoing Monitoring
Each TWPayz entity maintains risk-based systems and controls for the ongoing monitoring of business relationships and transactions throughout the customer relationship.
Monitoring is designed to identify unusual, potentially suspicious or otherwise inconsistent activity, taking into account the customer’s known business activities, risk profile, expected transaction behavior and other relevant financial crime risk indicators.
The nature and extent of ongoing monitoring are proportionate to the level of risk identified. Customer information, due diligence records and risk assessments are reviewed and updated periodically on a risk-sensitive basis and upon the occurrence of relevant trigger events, in accordance with applicable legal and regulatory requirements.
Where monitoring identifies activity requiring further review, appropriate measures may be taken in accordance with the relevant TWPayz entity’s internal procedures and applicable law.
7. Sanctions and Proliferation Financing
Each TWPayz entity maintains risk-based systems and controls designed to ensure compliance with applicable sanctions and proliferation financing laws, regulations and regulatory requirements.
Such controls include, as appropriate, screening customers, beneficial owners, authorised persons, counterparties and transactions against applicable sanctions requirements, together with the identification, assessment and mitigation of relevant sanctions and proliferation financing risks.
Where sanctions or other legal or regulatory restriction is identified, the relevant TWPayz entity will take appropriate action in accordance with applicable law and regulatory requirements. Such action may include rejecting or restricting a transaction, suspending or restricting a business relationship, freezing funds or assets where required, and making any required notification or report to the relevant competent authority.
8. Suspicious Activity Identification and Reporting
Each TWPayz entity maintains appropriate procedures for identifying, reviewing and escalating activity that may give rise to suspicion of money laundering, terrorist financing or other financial crime.
Where a reporting obligation arises, the relevant TWPayz entity submits the required reports or disclosures to the appropriate financial intelligence unit or other competent authority in accordance with applicable legal and regulatory requirements.
Information relating to suspicious activity and associated reporting is treated confidentially and handled in accordance with applicable legal restrictions on disclosure, including anti-tipping-off requirements.
9. Record Keeping
Each TWPayz entity maintains appropriate records relating to customer due diligence, transactions, ongoing monitoring and other relevant AML/CFT and financial crime matters in accordance with applicable legal and regulatory requirements.
Records are retained for the periods prescribed by applicable law and are maintained in a manner designed to ensure their confidentiality, integrity, security and availability for regulatory, supervisory or lawful investigative purposes, where required.
10. Governance and Controls
Each TWPayz entity maintains appropriate governance arrangements, policies, procedures and internal controls designed to identify, assess and manage money laundering, terrorist financing, proliferation financing and other relevant financial crime risks.
These arrangements include appropriate risk assessment, customer due diligence, ongoing monitoring, sanctions and PEP controls, suspicious activity reporting procedures, management oversight, staff training and compliance monitoring, in accordance with applicable legal and regulatory requirements.
The framework is reviewed periodically and updated as appropriate to reflect changes in applicable laws and regulations, business activities and financial crime risks.
11. Training
Each TWPayz entity maintains an appropriate AML/CFT and financial crime training program to ensure that relevant employees understand their responsibilities and remain aware of applicable financial crime risks and regulatory obligations.
Training is provided periodically and is tailored to employees’ roles and responsibilities. The training program is designed to reflect applicable legal and regulatory requirements, relevant financial crime risks, internal policies and procedures, and developments relevant to TWPayz’s business activities.
12. Third Parties
Where a TWPayz entity engages agents, introducers, service providers or other third parties in connection with its activities, appropriate risk-based due diligence, contractual controls and ongoing oversight are applied, taking into account the nature of the arrangement and applicable legal and regulatory requirements.
Each TWPayz entity remains responsible for ensuring compliance with the AML/CFT and financial crime obligations applicable to its regulated activities, including where relevant functions are performed or supported by third parties.
Customers introduced or onboarded through third-party or technology-enabled channels remain subject to the customer due diligence, risk assessment and ongoing monitoring requirements of the relevant TWPayz entity.
13. Cooperation with Authorities
Each TWPayz entity cooperates with competent regulatory, supervisory, financial intelligence and law enforcement authorities in accordance with applicable legal and regulatory requirements.
The relevant TWPayz entity provides information, documentation and assistance to competent authorities where required by applicable law or pursuant to the lawful exercise of their regulatory, supervisory or investigative powers.
14. Measures to Manage Financial Crime Risk
Each TWPayz entity reserves the right to take appropriate and proportionate measures where necessary to comply with applicable legal or regulatory requirements, fulfil its financial crime obligations, or identify, assess, manage or mitigate money laundering, terrorist financing, proliferation financing, sanctions, fraud or other financial crime risks.
Depending on the circumstances and subject to applicable law and contractual obligations, such measures may include:
Requesting additional information, documentation or clarification from a prospective or existing customer
Conducting additional or enhanced due diligence and verification
Declining an application or deciding not to establish a business relationship
Delaying, declining or restricting the processing or execution of a transaction where legally permitted or required
Suspending or restricting access to particular products, services or account functionality
Applying additional monitoring or other risk-mitigation measures
Restricting, suspending or terminating a business relationship in accordance with applicable law and contractual terms
Taking any other action required or permitted by applicable law, regulation or a competent authority
The nature and extent of any measures applied will depend on the circumstances, the financial crime risks identified and the legal and regulatory obligations applicable to the relevant TWPayz entity.
Where required, the relevant TWPayz entity may also make reports, disclosures or notifications to competent regulatory, supervisory, financial intelligence or law enforcement authorities.
Applicable law may restrict the relevant TWPayz entity from disclosing whether a review, investigation, report or other financial crime-related action has taken place or from providing detailed reasons for a decision, restriction or other measure applied.
15. Review
This Statement is reviewed periodically to ensure that it remains appropriate and reflects the legal and regulatory requirements applicable to each TWPayz entity.
It may be revised from time to time to reflect changes in applicable laws, regulations and regulatory guidance, developments in TWPayz’s business activities, and changes in the financial crime risk environment.
Contact
For enquiries relating to this Statement or TWPayz’s general approach to AML/CFT and financial crime compliance, please contact:
Email (UK): legal@twpayz.com
Email (Mauritius): legal_mru@twpayz.com
Enquiries will be directed, where appropriate, to the relevant TWPayz entity in accordance with its respective regulatory responsibilities.
Customer service enquiries, account-related matters and complaints should be submitted through the appropriate contact channels specified on the TWPayz website or in the applicable customer terms.