AML/KYC

Why does Sentro Payment require your KYC documents?

Sentro Payment is committed to maintaining the highest standards of integrity, security, and regulatory compliance. Our Know Your Customer (KYC) and Anti-Money Laundering / Counter-Terrorist Financing (AML/CFT) framework is designed to prevent money laundering, terrorist financing, and other financial crimes.

Collecting and verifying KYC documentation enables Sentro Payment to meet its legal and regulatory obligations while protecting our platform, our merchants, and the wider financial ecosystem. These measures allow us to identify, assess, and mitigate potential risks effectively.

KYC documentation is required to authorise access to any Sentro Payment product or service, including IBAN accounts, card processing solutions, and alternative payment methods (APMs).

Providing complete and accurate information at the outset helps streamline the verification process and avoids unnecessary delays. Our merchants can operate with confidence, knowing that Sentro Payment applies robust compliance standards to protect their business interests.

Requirements for the implementation of the policy

Sentro Payment’s AML/CFT policy, including any material amendments, is approved by the Board of Directors in accordance with the applicable local legislative framework of Furious Valley Trading Pvt. Ltd.

KYC rules and AML/CFT regulations issued by Furious Valley Trading Pvt. Ltd establish clear requirements for identifying, reviewing, and reporting unusual or suspicious transactions to the relevant authorities. Where indicators of money laundering, terrorist financing, or related financial crimes are identified, Sentro Payment ensures timely notification to Furious Valley Trading Pvt. Ltd.

Both on-site and off-site supervision is conducted across all branches and subsidiaries to ensure effective implementation of AML/CFT controls. Internal policies and procedures are regularly reviewed to maintain ongoing compliance.

Employee training is a key component of our compliance programme. AML/CFT training plans are developed in coordination with the Human Resources Department and implemented across the organisation to ensure employees understand their responsibilities and can identify and escalate potential risks.

At least once per year, a comprehensive AML/CFT activity report is submitted to the Money Laundering Reporting Officer (MLRO). Following review and assessment, the report and any required actions are shared with Furious Valley Trading Pvt. Ltd.

The process of verifying a customer’s identity (KYC)

Customer identification is a fundamental requirement at the start of any business relationship and is essential for compliance with KYC and anti-money laundering regulations.

The customer verification process is guided by the following key principles:

• Customers must provide original and valid identification documents. For legal entities, this applies to all relevant members or authorised representatives.
• All KYC records are securely stored and maintained in a centralised system.
• Customer risk factors are assessed, including background, country of origin, political exposure, connected accounts, business activities, and other relevant indicators.
• Transactions involving intermediaries or related third parties are carefully reviewed due to potential reputational and operational risks.
• Customer records must remain accurate, complete, and up to date throughout the business relationship.

If verification issues arise that cannot be satisfactorily resolved, Sentro Payment reserves the right to terminate the business relationship and return funds to the original source in accordance with applicable laws and regulations.

Sentro Payment does not open accounts or conduct business with individuals or entities that request anonymity or provide false or misleading information. Until the KYC process is fully completed, an individual or entity will not be recognised as a customer.

Acceptance policy for customers

Sentro Payment ensures that its sales and onboarding teams have a comprehensive understanding of each customer’s Know Your Customer (KYC), Know Your Business (KYB), and overall risk profile prior to acceptance. This structured approach enables the company to identify, assess, and mitigate potential risks related to money laundering or terrorist financing.

As part of the customer screening process, Sentro Payment verifies that all data and documentation submitted to the system are accurate, complete, and authentic. Customers are assessed using a risk-based methodology and are categorised according to predefined risk levels (Low, Medium, or High), in line with applicable legal and regulatory requirements.

Ongoing customer due diligence

Sentro Payment applies a risk-based approach to ongoing customer due diligence. Customer information is reviewed periodically to ensure it remains accurate, current, and relevant, with enhanced monitoring applied to higher-risk customer categories.

For standard-risk customers, periodic KYC reviews are conducted based on an “awareness principle” following an initial assessment by the AML team. This process requires the customer’s account manager to regularly review and confirm the customer’s profile, activities, and risk indicators as part of routine customer relationship management.

Ongoing transaction monitoring

The AML and Compliance teams ensure that continuous transaction monitoring is performed to identify unusual, anomalous, or suspicious activity. Transactions are assessed against the customer’s established risk profile, expected behaviour, and business activity.

Sentro Payment will keep track of transactions on two levels

The Front Line of Defence: Sentro Payment empowers its frontline teams to act as the first line of defence against suspicious activity. Any interaction with a customer, account holder, or authorised agent may trigger enhanced due diligence on the associated account or transaction.

Examples include requests to execute financial transactions, claims related to payment methods, or account service enquiries. In such cases, due diligence is applied by the customer success team, where necessary in coordination with the Compliance Manager.

Transactions are assessed based on the customer’s KYC profile, financial behaviour, transaction counterparties, and overall activity pattern. Atypical transactions are those for which the lawful purpose or source of funds cannot be reasonably established. Any Sentro Payment employee who identifies transactions that cannot be linked to legitimate activity or a known source of income must escalate the matter to the AML team without delay.

Sanctions screening: Sentro Payment operates a robust sanctions screening framework, including automated name-matching mechanisms that compare customer data against official sanctions lists issued by Furious Valley Trading Pvt. Ltd, the European Union, OFAC, and the United Nations.

In addition, transactions involving foreign banks are screened through online systems to ensure compliance with international sanctions obligations.

Sentro Payment also maintains an internal Country Watchlist to provide all business units with up-to-date information on jurisdictions subject to sanctions, embargoes, or elevated risk. This includes:

• Countries subject to economic or trade sanctions imposed by China, including sanctioned persons, entities, or transactions
• Countries sanctioned by the European Union, including sanctioned persons, entities, or transactions
• United States-designated sanctions jurisdictions, including sanctioned persons, entities, or transactions
• Countries identified by international bodies (such as the FATF) as having a higher risk of money laundering
• Jurisdictions regarded by Hong Kong authorities and the Financial Intelligence Unit (FIU) as tax havens

Enterprise-wide assessment

Sentro Payment’s compliance management framework incorporates risk assessment as a core component. In line with its risk-based approach, Sentro Payment conducts an AML Enterprise-Wide Risk Assessment (EWRA) to identify, analyse, and evaluate risks specific to the organisation and its individual business lines.

Following the identification and documentation of risks associated with products and services, an overall AML risk profile is established. This assessment considers multiple factors, including customer types, transaction behaviour, distribution channels, geographic exposure, revenue sources, and emerging qualitative risks.

Regulatory requirements, supervisory expectations, and relevant industry guidelines are used as reference points to classify and assess AML/CFT risk categories.

Calculation of the risk profile

A compliance risk profile is assigned at the commencement of each business relationship and categorised as Low, Medium, or High. This risk profile is reviewed and recalculated on an ongoing basis, depending on changes in customer behaviour or risk indicators, to determine the appropriate level of AML/CFT due diligence required.

What documents count under KYC?

KYC verification may require the collection and review of documents to confirm a customer’s identity, residential address, and, where applicable, biometric identification. These documents are used to validate authenticity and ensure compliance with regulatory standards.

Staff protection guarantee: Employees who report suspicious or questionable transactions in good faith are fully protected under Sentro Payment’s internal policies.

Internal control of organisation

Reporting of suspicious transactions: Sentro Payment provides detailed guidance and procedures to its employees on when and how suspicious transaction reports must be raised. All reports are subject to a thorough review by the Sentro Payment AML team in accordance with established internal controls.

Based on the outcome of the investigation and information obtained, Furious Valley Trading Pvt. Ltd’s AML team will determine whether a report should be submitted to the Financial Intelligence Unit (FIU).

There is no threshold or limitation on the value or type of transactions that may be reported, irrespective of whether they are suspected of money laundering or terrorist financing.

Each report must clearly document the facts and circumstances that gave rise to the suspicion.

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

Information relating to suspected money laundering or terrorist financing must not be disclosed to the customer, beneficial owner, or any third party, except to competent authorities and enforcement agencies in accordance with applicable AML laws.

Policies & procedures

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

Sentro Payment retains AML/CFT documentation for a minimum period of five years. This includes unusual and suspicious transaction reports, together with evidence demonstrating that such reports were reviewed and assessed.

Records maintained include copies of suspicious transaction documentation, reports submitted to Furious Valley Trading Pvt. Ltd, and any additional documentation retained at the discretion of the Head of Compliance. Original records are securely archived in accordance with record retention policies.

Training records must document all AML/CFT programmes delivered to employees, including participant names, departments, training content, duration, and the training provider, whether domestic or international.

Training and ongoing awareness

Sentro Payment implements continuous training and awareness programmes to ensure employees remain informed of their AML/CFT responsibilities. These programmes are updated regularly to reflect regulatory developments and emerging risks.

Mandatory AML e-learning and instructor-led training is provided, including:

• Compulsory AML training for all new employees as part of the onboarding process
• Role-specific AML and KYC training tailored to the nature of the employee’s responsibilities
• Workshops led by experienced members of Sentro Payment’s AML team

Through these measures, Sentro Payment supports its clients in reducing financial crime risk while maintaining full compliance with AML, BSA, and related regulatory obligations. While compliance responsibilities cannot be fully delegated, Sentro Payment strives to minimise the operational burden on its clients wherever possible.

With Sentro Payment as a trusted compliance partner, clients can be confident that their operations align with applicable AML and regulatory standards. Additional guidance is available through Sentro Payment’s documentation or by contacting customer support.