Lopay AML & Fraud Prevention Program
This site summarizes the policies and procedures in place, which comprise Lopay’s AML and Fraud Prevention Program.
Lopay’s Anti-money-laundering (AML) policies and procedures exist to combat money laundering by stopping criminals from engaging in transactions to disguise the origins of funds connected to illegal activity.
Lopay’s AML Policy helps the company to comply with AML and counter-terrorism financing laws and regulations. Anti-money laundering policies and procedures help to set the tone for the organization and reinforce a culture of compliance.
AML Compliance Officer
Lopay is in the process of being registered with FCA and does not have a legal requirement to appoint an AML Compliance Officer. However, to ensure the company has put in place robust AML and fraud prevention Policies an AML Compliance Officer has been appointed. Contact: [email protected].
KYC, AML & Fraud Prevention Policies
Lopay has a number of Policies and Procedures covering Onboarding KYC and transacting monitoring.
Onboarding KYC
Lopay collects a range of information during the onboarding of customers to verify their information. For more information on what information is collected see the document “Lopay Account Verification and KYC” (Lopay Limited)
Managing risk
All business owners assume a certain amount of risk when accepting payments for goods and services. For more information on how Lopay manages risk, see the document “Lopay Onboarding: Managing Risk” (Lopay Limited)
Transaction & Account Monitoring & Restricted Businesses
Lopay actively monitors all accounts for suspicious or irregular activity. Precise technical details are confidential as knowledge of such monitoring programs could be used to circumvent monitoring by bad actors. The monitoring that is conducted can be summarised by looking at what key strategies the monitoring focuses on
| Description | Monitoring Strategy |
|---|---|
| Transaction size | Large transaction sizes are higher risk, and as such unusually high transaction size for a business category may result in automatic account review or suspicion |
| Chargebacks | Fraudulent activity isn’t just associated with Fraudulent chargebacks, so all types of chargebacks are monitored. |
| Business activity | Certain businesses and business activities are prohibited from the Lopay platform. For more information see the “Lopay: Restricted Businesses” document. (Lopay Limited) |
| User behavior | How the user interacts with the app acts as an indication of the risk profile of the user. For example, a user who signs up and quickly attempts to accept large e-commerce payments affect the risk score. |
| Location | The location of the merchant and the source location of transactions is a key input into the risk profile of a transaction and merchant. Location is determined by a number of factors such as card country, IP address, and physical mobile device location data. |
| External accounts (banks) & payouts | Different banks and payout schedules have different risk profiles associated with them. For example, faster payout schedules and certain challenger banks have higher risk profiles. |
| Transaction sources | Multiple charges from the same or similar sources is a key indicator of a high-risk account |
| Blocked lists and account metadata | Historical records such as block lists and data associated with blocked accounts is used as input to assess the risk score of active and new accounts |
Staff training
All Lopay staff are trained to increase awareness of common concerns such as unexpectedly large transactions, suspicious customer details, or odd account behavior.
Refresher training is conducted quarterly, to ensure staff are up to date with the latest industry trends and are assessed in order to demonstrate their ability to apply the training to their role.
Testing and auditing
Lopay’s AML and fraud prevention policies are self-assessed and reviewed on a quarterly basis.