— KYC / AML

This KYC/AML Policy outlines the principles and procedures applied by Flopays UAB (“Company”, “we”, “our”), the operator of Paybin.io, to comply with international standards on anti-money laundering (AML) and counter-terrorist financing (CTF), and to implement robust Know Your Customer (KYC) protocols.

1. Purpose

The purpose of this policy is to:

  • Prevent the use of our platform for money laundering or terrorist financing.

  • Comply with the applicable laws and regulations in the Republic of Lithuania and the European Union.

  • Detect and report suspicious activities in a timely manner.

  • Ensure that all users are properly verified before accessing services.

2. Regulatory Framework

This Policy is based on:

  • The Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing

  • The EU’s 5th Anti-Money Laundering Directive (5AMLD)

  • FATF Recommendations

  • Guidelines from the Lithuanian Financial Crime Investigation Service (FCIS)

3. Customer Due Diligence (CDD)

We apply different levels of Customer Due Diligence (CDD) based on a risk-based approach:

a. Standard Verification

Required from all users:

  • Full legal name

  • Date of birth

  • Country of residence

  • Email and phone number

  • Government-issued ID document (passport or national ID)

b. Enhanced Due Diligence (EDD)

Required for:

  • High-risk countries or politically exposed persons (PEPs)

  • Transactions exceeding regulatory thresholds

  • Suspicious or unusual activities

EDD may include:

  • Proof of address (utility bill, bank statement)

  • Source of funds/income

  • Live video verification

4. Ongoing Monitoring

We continuously monitor user activity to detect:

  • Unusual transaction patterns

  • Sudden changes in user behaviour

  • Structuring of transactions to avoid thresholds

We may request re-verification or temporarily suspend accounts pending review.

5. Sanctions and Blacklists

We screen all users and transactions against:

  • EU and OFAC sanctions lists

  • UN Security Council Resolutions

  • Other relevant PEP/sanctions/watchlists

Access to our services is strictly prohibited for individuals or entities listed on such sanctions registers.

6. Record Keeping

In compliance with AML regulations, we retain the following records for a minimum of 8 years after the end of a user relationship:

  • KYC documents and communications

  • Transaction logs and account activity

  • Risk assessments and internal reports

These may be provided to competent authorities upon lawful request.

7. Training and Awareness

All employees and contractors are:

  • Trained regularly on AML/KYC procedures

  • Required to report any suspicious activity immediately to the AML Compliance Officer

8. Suspicious Activity Reporting

We are obligated to submit Suspicious Activity Reports (SARs) to the Financial Crime Investigation Service (FCIS) of Lithuania when:

  • There are reasonable grounds to suspect criminal intent

  • A user refuses to provide required information

  • A transaction appears to be designed to conceal illicit origin

9. Compliance Officer

We have appointed an AML Compliance Officer who is responsible for:

  • Overseeing the implementation of this Policy

  • Ensuring ongoing regulatory compliance

  • Coordinating internal audits and investigations

  • Acting as the point of contact for regulators

10. User Responsibilities

By using our Services, you agree to:

  • Provide truthful and complete information during onboarding

  • Promptly update any personal or business information

  • Cooperate with all verification and monitoring procedures

Failure to comply may result in the suspension or termination of your account.

11. Policy Review

This Policy is reviewed and updated at least annually or whenever there are changes to relevant laws or risk conditions.

12. Contact

If you have any questions or concerns regarding this Policy, please contact us:

📧 compliance@paybin.io
📍 Flopays UAB, Žalgirio g. 88-101, 09303 Vilnius, Lithuania