Prohibited industries / activities should include but are not limited to:
UBank Connect List of Prohibited Countries:
Note: The list above is based on restricted, non-cooperative countries and sanctioned countries by the Financial Action Task Force (FATF) and being updated quarterly.
1. General Policies
2. Anti-Money Laundering General Policy – UBank Connect
Each member of the UBank Connect must have a Manual for the Prevention of money laundering and terrorist financing, either individually or as a part of a common manual, which should be updated whenever changes in the legislation or internal rules are produced.
Determination of risk profiles by activity
The following factors shall be taken into account to assign the risk profiles:
1. Purpose
2. Policy Statement
UBank Connect requires all the members of UBank Connect holding any Clients’ Money on behalf of a client to comply with this policy in its entirety.
3. Definition of Terms
UBank Connect sometimes has power or control over a client’s own account. Even though this does not strictly meet the definition of Clients’ money, UBank ensures that it has the specific written authority of the client acknowledged by the Connect must bank before exercising the authority, and it must maintain adequate records of the transactions it undertakes.
For the purpose of this policy, clients’ money does not include:
4. Client Identification
Before holding any Clients’ money on behalf of a client, UBank Connect must first verify the identity of the client.
Guidance
Converting or concealing criminal property or terrorist funds, for example by allowing them to be passed through a client’s money account, is a criminal offense. However, no offence is committed if a prompt report is made, when this is suspected, to the law enforcement authorities and their permission obtained to continue the transaction. More guidance on the recognition of when this might be the case, and advice on reporting money laundering suspicions, is contained in UBank Connect’s Anti-Money Laundering and Counter-terrorist Financing Policies.
Where Clients’ money is held for the first time after the implementation date of this policy, on behalf of someone who was already a client at that date, UBank Connect should consider carefully if it has sufficient evidence of the client’s identity from previous dealings.
Under UBank Connect’s Anti-Money Laundering and Counter-terrorist Financing Policies and the UBank Connect’s respective manuals implementing the same in particular jurisdictions, UBank Connect must verify the identity of all new clients. This would meet the identification requirements outlined above.
5. Opening a Settlement Bank Account
All money, including clients’ money, received in relation to the transaction must be held in UBank Connect’s settlement bank account. Where UBank Connect receives or holds clients’ money or mixed monies or monies which it is required to pay into a client account, it must take note of the clients’ bank accounts. UBank Connect must take note that a client may maintain one or more client bank accounts as appropriate and should, therefore, consider the necessary bank details.
On opening a settlement bank account, UBank Connect must notify the bank that:
For a settlement account located in any jurisdiction, if the bank does not allow the settlement to be made within twenty (20) days from notice thereof, UBank Connect must:
UBank Connect may hold money in a bank outside its territory provided that:
6. Payment into a client bank account
Clients’ money or mixed monies received by UBank Connect must be paid immediately into a client bank account or to the client, if necessary.
UBank Connect must pay money into a client’s bank account, different from that previously declared in
an appropriate contract, only if:
UBank Connect shall not be regarded as having breached this policy simply because it transpires that money it paid into a client bank account in the reasonable belief that it was required so to do under this policy, as well as under an agreement with the client, should not have been paid into such an account, provided, that immediately upon discovering the error, UBank Connect takes the necessary steps to withdraw the money that has been paid in error.
Where money of any one client in excess of USD 10,000 is held or is expected to be held by UBank Connect for more than thirty (30) days the money must be paid into a client bank account designated by the name of the client or by a number or letters allocated to that account. (Note: The client bank account in this paragraph must be in a separate bank account, rather than a memorandum account in UBank Connect’s book. In other words, the account will be for that client, or clients acting jointly, only).
7. Withdrawal from client’s bank account
UBank Connect may withdraw from a client bank account:
Guidance
This paragraph sets out the various circumstances in which money may be withdrawn from clients’ bank account. It requires such withdrawals to be permitted by an authorized officer of UBank Connect. The written delegation should specify any restrictions on its use. In deciding who can have this authority, UBank Connect must consider the trust that is being placed in the individual and their ability to carry out this function with due care and integrity. UBank Connect remains responsible for the entire UBank Connect’s compliance with the client’s money policy, regardless of any delegation they have made. UBank Connect should also review the entire UBank Connect’s compliance with related regulations, which review should include the operation of any delegated powers.
Clients’ money must be returned to the client promptly as soon as there is no longer any
reason to retain it.
Money may not be withdrawn from a client’s bank account for or towards payment of fees payable by the client to UBank Connect unless:
Monies that are payable to UBank Connect must be withdrawn as soon as reasonably practicable.
This policy governs the treatment and withdrawal of fees from monies held for the clients before settlement to the clients’ bank account. It does not relate to commissions received by any person or company to whom UBank Connect transacted with.
8. Records and Reconciliations
UBank Connect must keep clients’ money records (including any notice and acknowledgments under
this policy) that show the following:
UBank Connect must:
Returns and Reports UBank Connect must:
Where possible, the review should be conducted by a UBank Connect authorized officer who is not
involved in the handling of clients’ money.
Employees must report significant breaches of this policy to UBank Connect management.
To enable the client, as well as any proper government office, to ascertain whether or not this policy is being complied with, UBank Connect may:
It is the responsibility of UBank Connect and the entire UBank Connect to make books and records available for inspection in accordance with such a Notice and/or to provide an Independent Accountant’s Report in accordance with any such requirement.
9. Other Responsibilities
UBank Connect shall be responsible for any breach of this policy on the part of the entire UBank Connect unless it has been proven that the responsibility for the breach is entirely that of another party not within its control.
UBank Connect shall also be responsible for companies that are wholly or partly controlled by it, whether directly or indirectly, and which may receive or hold Clients’ money pursuant to an arrangement with UBank Connect that enables the proper distribution or processing of Clients’ money. Any member of UBank Connect must notify UBank Connect of these arrangements and should apply for a license renewal process, if required, following any change (including cancellation) in the arrangement.
10. Unidentified and untraced clients
Where UBank Connect has been unable, after taking reasonable steps over at least five (5) years, to trace a client, any unclaimed monies need no longer be treated as the client’s money. UBank Connect may then donate the monies to a registered charity, subject to the following conditions:
Where UBank Connect is ceasing to practice, payment of any unclaimed clients’ money to a registered
charity must be on the following terms:
On cessation, UBank Connect must inform the proper government authority in writing of all sums paid to a registered charity in accordance with this policy. The information must include:
For the purpose of paragraph 36, ceasing to practice does not include any arrangement whereby UBank Connect succeeds in the business of another.
Any sums not paid to a registered charity in accordance with paragraphs 34 and 35 must be retained on deposit for the benefit of the unidentified or untraced client unless when the parties have made a written arrangement about what would happen should such circumstances arise.
UBank Connect has implemented stringent Fraud Detection measures:
A comparison of key values in the transaction message is performed between the data sent by the Merchant and the data returned by the Bank
UBank Connect Payment & Security Additional Services API
The UBank Connect System provides an additional service in the API that is intended to assist merchants in performing security checks, card verification, customer ID verification, features that would help to eliminate fraudulent actions, third-party deposits, and other actions that would generate chargebacks or perturb their processing activity.
Credit Card Verification
This service is used to help the merchant in performing a check on the credit card account and validate the corresponding customer. This helps to reduce or eliminate third-party deposits. The method involves a transaction with a small secret random amount (1.00 – 4.00) in the customer’s card currency. After the transaction is completed and the amount is generated in the customer’s card statement (usually no longer than 24-48 hours) the customer should input the secret amount used in the verification and would validate his card account.
To implement this method:
Escalation Procedure
Escalation is a critical part of Merchant Support (MS) operations. Each MS team member must fully understand what, when, why, and how to escalate issues. MS team members must make good decisions and show sound judgment depending on the severity of the issue.
Why do we need to escalate?
Although escalation is an occurrence that we do not want to happen and should be our last resort, it is an inevitable part of our business process. This escalation procedure aims to help each team member how to identify an issue and take the proper course of action.
This process is applicable to all types of payment solutions that UBank Connect offers.
For more information and inquiries, please contact our AML Officer, Reymart M. at reymart@ubankconnect.com and risk@ubankconnect.com
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