Anti-Money Laundering (AML) Policy and Procedures

PAYBLIS SAS
Registered in France

1. Policy Statement

Payblis SAS is committed to preventing the use of its services for money laundering, terrorism financing, and other criminal activities. In compliance with French and EU regulations, including but not limited to the 5th Anti-Money Laundering Directive (EU) 2018/843 and the French Monetary and Financial Code, we implement robust procedures and internal controls to identify and mitigate these risks.

2. Scope

This policy applies to all business relationships, clients, partners, and transactions processed via Payblis SAS. It covers Know-Your-Customer (KYC) procedures, risk-based monitoring, suspicious activity reporting, record keeping, and internal responsibilities.

3. Customer Due Diligence (CDD)

Payblis SAS applies a risk-based approach to CDD. We verify the identity of all clients, whether individuals or legal entities, before initiating any business relationship.

Required Information:

• For individuals: Government-issued ID, proof of address.

• For companies:

  • Company registration certificate

  • Identity documents of UBOs (25%+ shareholding), directors

  • Proof of business bank account

Where applicable, online or in-person verification is conducted. If verification fails, the business relationship is refused.

4. Risk-Based Approach

We assess each client and transaction based on several risk factors:

• High cash-volume activities

• Complex or opaque ownership structures

• Jurisdiction of client

• Nature and size of transactions

High-risk clients or transactions are either subject to enhanced due diligence or rejected.

5. Ongoing Monitoring

Client accounts and transactions are reviewed regularly. Monitoring focuses on:

• Unusual transaction patterns

• Sudden changes in business activity

• Inconsistent information

• Payments to or from high-risk jurisdictions

Clients must provide updated KYC documents when required.

6. Suspicious Activity Reporting (SAR)

If a suspicion of money laundering arises, the MLRO will assess the situation and submit a SAR to the competent French authority (TRACFIN).

7. Internal Responsibility

The appointed Money Laundering Reporting Officer (MLRO) is:

Jonathan Petit
CEO & MLRO, Payblis SAS
[[email protected]]

The MLRO is responsible for:

• Ensuring staff awareness

• Reviewing KYC files

• Reporting to TRACFIN

• Updating this policy as required

8. Record Keeping

All KYC, transaction and compliance documents are retained for 5 years after the end of the business relationship. All records are securely stored and accessible for regulatory inspection.

9. Staff Awareness

Due to the current size of Payblis SAS, the MLRO is the sole compliance officer. However, in the event of future recruitment, new employees will be trained on:

• AML regulations

• Their individual obligations

• Internal procedures for escalating suspicious activity

10. Review and Updates

This policy is reviewed annually or upon regulatory changes. Last updated: June 2025.

Approved by:
Jonathan Petit
Founder & CEO – Payblis SAS
Date: 13/06/2025