1. Policy Overview
VaultPay maintains risk-based AML/CFT controls across onboarding, transaction monitoring, and reporting.
2. Regulatory Framework
AML Act 2010, Anti-Terrorism Act 1997, SBP PSP Regulations, and FATF 40 Recommendations.
3. KYC / CDD
Required records include CNIC, NTN, business registration, and beneficial ownership declarations.
4. Transaction Monitoring
5. SAR Reporting
Suspicious Transaction Reports are escalated and filed to FMU within 7 working days.
6. Sanctions Screening
Screening includes UN, OFAC, Pakistan First Schedule, EU, and UK sanctions lists.
7. Enhanced Due Diligence
EDD is applied to high-risk sectors, high-volume entities, and unusual transaction patterns.
8. Record Keeping
Records are retained for 7-10 years under applicable regulations.
9. Staff Training
Ongoing training programs are required for all customer-facing and risk personnel.
10. Compliance Officer
Contact: compliance@vaultpay.pk
Tipping off customers about investigations is strictly prohibited.