Disclaimer

Why Does Sentro Payments Require Your KYC Documents?

Sentro Payments’ Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework is designed to establish clear regulatory standards and mitigate financial crime risks. Our comprehensive policies and procedures ensure that money laundering and terrorist financing risks are effectively identified, assessed, and controlled. To uphold these standards, all employees, management, and affiliated entities are required to comply with strict AML/CFT compliance obligations.

KYC documentation is required to verify and authorize access to any Sentro Payments service, including IBAN accounts, card payment processing solutions, and alternative payment methods (APMs). This verification process is a regulatory requirement and a critical component of maintaining a secure and compliant payment ecosystem.

Collecting complete and accurate information at the verification stage allows us to streamline approvals and reduce delays. With Sentro Payments, merchants can operate with confidence, knowing their accounts are supported by a secure, compliant, and trusted financial infrastructure.

Requirements for the Implementation of the Policy

Any material changes to Sentro Payments’ Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) policy must be approved by the Board of Directors and the relevant local legislative and regulatory authorities. Sentro Payments adheres to AML/CFT regulations and internal rules issued by Furious Valley Trading Pvt. Ltd, which provide the framework for identifying, reviewing, and reporting unusual or suspicious transactions to the appropriate authorities.

In cases involving suspected money laundering, terrorist financing, or related financial crime, Sentro Payments reports such transactions to Furious Valley Trading Pvt. Ltd in accordance with applicable AML/CFT requirements. Both off-site and on-site supervision is conducted across all branches and subsidiaries to ensure effective internal controls. AML/CFT training programs are developed in coordination with the Human Resources Department and delivered to employees on a regular basis. The implementation and effectiveness of these measures are reviewed and reported annually to the Money Laundering Reporting Officer (MLRO), who evaluates the findings and takes appropriate action before submission to Furious Valley Trading Pvt. Ltd.

The Process of Verifying a Customer’s Identity (KYC)

To comply with Know Your Customer (KYC) and AML/CFT regulations, customer identification is conducted at the outset of any business relationship. Original identification documents are required from all customers, including authorized representatives of legal entities, and these records are securely maintained. Sentro Payments assesses customer background, country of origin, business activity, political exposure, connected accounts, and other relevant risk indicators as part of the verification process.

Transactions involving intermediaries or third parties are subject to enhanced scrutiny, as they may present increased operational or reputational risk. Customer records must remain accurate and up to date throughout the relationship. If verification issues cannot be resolved, Sentro Payments reserves the right to terminate the relationship and return funds to the original source. Accounts will not be opened, nor services provided, to any individual or entity requesting anonymity or providing false or misleading information. Completion of the KYC process is mandatory; without it, an individual or entity cannot be recognized as a customer.

Acceptance Policy for Customers

Sentro Payments ensures that its sales and onboarding teams maintain a comprehensive understanding of each customer’s KYC and KYB information, as well as the associated risk profile. This approach enables the company to prevent involvement in money laundering, terrorist financing, or other prohibited activities.

As part of the customer acceptance process, all submitted data and documentation are reviewed to confirm accuracy and authenticity. Customers are classified using Sentro Payments’ risk-based methodology in accordance with legal and regulatory obligations. Each customer is assigned a risk level—Low, Medium, or High—which determines the level of due diligence and ongoing monitoring applied throughout the business relationship.

Ongoing Customer Due Diligence

Sentro Payments applies a risk-based approach to ongoing customer due diligence to ensure that customer information, particularly for higher-risk categories, remains accurate and up to date. For standard-risk customers, periodic KYC reviews are conducted based on an “awareness principle,” following the AML team’s review of the customer file.

This process requires customer account managers to perform regular KYC assessments as part of ongoing customer relationship management, ensuring that any changes in customer activity, risk profile, or business operations are promptly identified and addressed.

Ongoing Transaction Monitoring

The AML and Compliance team ensures that continuous transaction monitoring is conducted to identify unusual or suspicious activity when compared against the customer’s established risk profile and expected behavior.

Sentro Payments monitors transactions through a multi-layered approach:

• Front Line of Defence: Sentro Payments alerts its operational teams to potential indicators of suspicious activity. Any interaction with a customer, account holder, or authorized representative triggers enhanced due diligence where appropriate. This includes requests related to financial transactions, payment methods, or account services. Transaction behavior is assessed based on the customer’s KYC profile, financial activity, transaction counterparties, and historical behavior. Transactions that cannot be reasonably linked to legitimate business activity or a verifiable source of funds are considered atypical and must be escalated. Any employee identifying such activity is required to report it immediately to the AML function.
• Sanctions Screening: Sentro Payments utilizes automated name-screening and list-matching mechanisms to compare customer data against official sanctions lists issued by Furious Valley Trading Pvt. Ltd, the European Union, OFAC, and the United Nations. Transactions involving foreign banks are also screened through external systems to ensure full compliance with applicable sanctions requirements.

In addition, Sentro Payments maintains and regularly updates an internal Country Watchlist to provide all business units with current information on high-risk and restricted jurisdictions. This includes:

• Countries subject to economic or trade sanctions imposed by China, including sanctioned individuals, entities, or transactions;
• Countries and parties sanctioned by the European Union;
• United States-designated sanctions jurisdictions, including sanctioned persons, entities, or transactions;
• Jurisdictions identified by international authorities such as the FATF as presenting elevated money laundering risks;
• Countries identified by Hong Kong authorities and the Financial Intelligence Unit (FIU) as tax havens.

Enterprise-Wide Assessment

Sentro Payments’ compliance management framework includes risk assessment as a core component. As part of its risk-based approach, Sentro Payments conducts an AML enterprise-wide risk assessment to identify, analyze, and evaluate risks specific to the company and its various business lines.

Following the identification and documentation of risks associated with the company’s products and services, an overall AML risk profile is established. This assessment considers multiple risk factors, including:

The types of customers served; the products and services offered; transaction volumes and patterns; distribution channels; geographic locations of operations, customers, and revenue sources; as well as other qualitative and emerging risks relevant to the business.

Regulatory requirements, supervisory expectations, and applicable industry guidelines are used as benchmarks to categorize and assess AML/CFT risk levels.

Calculation of the Risk Profile

A compliance risk profile is assigned at the commencement of each business relationship and categorized as Low, Medium, or High. This risk profile is reviewed and recalculated on an ongoing basis, taking into account changes in customer behavior, transaction activity, or risk exposure, to determine the appropriate level of AML/CFT due diligence required.

What Documents Count Under KYC?

KYC verification may require the review of official documents to confirm a customer’s identity, address, and, where applicable, biometric information.

• Staff Protection Guarantee: Employees who report suspicious or questionable transactions in good faith are protected by the company in accordance with internal whistleblowing and compliance policies.

Internal control procedures within the organization include the following:

• Reporting of Suspicious Transactions: Sentro Payments provides clear guidance and instructions to staff on when and how to report suspicious activity. All reported transactions are reviewed in detail by the Sentro Payments AML team in accordance with established internal procedures.

Based on the findings of the internal investigation, Furious Valley Trading Pvt. Ltd’s AML team determines whether a report should be submitted to the Financial Intelligence Unit (FIU).

There is no minimum threshold or limitation on the type or volume of transactions that may be reported, regardless of whether the suspicion relates to money laundering or terrorist financing.

Each report includes a comprehensive explanation outlining the reasons for suspicion.

Sentro Payments is responsible for submitting reports in the format prescribed by Furious Valley Trading Pvt. Ltd. Such reports include all relevant transaction details and supporting documentation.

Information relating to suspected money laundering or terrorist financing must not be disclosed to the client, beneficial owner, or any unauthorized third party. Disclosure is permitted only to competent authorities and entities responsible for the enforcement of applicable anti-money laundering laws.

Policies & Procedures

Sentro Payments maintains comprehensive AML/CFT policies and procedures on its internal intranet portal. These policies translate regulatory AML/CFT requirements, including minimum KYC standards, into clear operational guidelines for day-to-day implementation.

Sentro Payments retains the following documentation for a minimum period of five (5) years, in accordance with applicable regulatory requirements:

Records of unusual and suspicious transaction reports, including supporting documentation demonstrating that such reports have been reviewed and assessed.

Copies of suspicious transaction documentation are maintained by Sentro Payments, while original records are stored in the company’s archives. This includes copies of reports submitted to Furious Valley Trading Pvt. Ltd, as well as any additional documentation retained by the Head of the Compliance Department.

Training records are also maintained and include details of all AML/CFT training programs delivered to employees, such as participant names, departments, training content, duration, and the training provider, whether domestic or international.

Ongoing Training

Sentro Payments implements continuous training and awareness programs to ensure employees remain informed of their AML/CFT obligations. These programs are regularly updated to reflect regulatory developments and include mandatory AML e-learning modules.

• All new employees are required to complete AML onboarding training.
• AML and KYC training is tailored to the nature of the employee’s role and business function. Training sessions are conducted by members of the Sentro Payments AML team with specialized expertise in anti-money laundering and compliance.

Through these initiatives, Sentro Payments supports its clients in mitigating financial crime risks while ensuring adherence to applicable AML and compliance regulations. Our objective is to reduce the compliance burden for our clients wherever possible while maintaining the highest regulatory standards.

With Sentro Payments as your compliance partner, you can operate with confidence knowing that AML, BSA, and related regulatory requirements are being addressed effectively. For further guidance, clients may consult Sentro Payments’ documentation or contact our customer support team for assistance.