1. Purpose
The purpose of this policy is to ensure that Bayarcash complies with all applicable sanctions and watchlist regulations by screening merchants, transactions, and business partners against relevant lists to prevent illicit activities.
2. Scope
This policy applies to:
- All merchants, counterparties, and business partners of Bayarcash.
- All transactions processed through Bayarcash systems.
- All Bayarcash employees responsible for onboarding, compliance, and transaction monitoring.
3. Policy Statement
Bayarcash is committed to:
- Screening all merchants and transactions against relevant sanctions lists (local, international, and regulatory).
- Preventing the facilitation of transactions involving sanctioned individuals, entities, or countries.
- Reporting any positive matches to the Compliance & Risk Team and relevant authorities as required by law.
- Maintaining audit trails of all screenings for regulatory and internal review.
4. Screening Process
Bayarcash applies a robust sanctions screening framework to ensure merchants and transactions do not involve prohibited or high-risk parties, supporting compliance with regulatory and international requirements.
| Activity | Description |
|---|---|
| Merchant Onboarding | Screen all new merchants against up-to-date sanctions and watchlists. |
| Ongoing Monitoring | Conduct periodic reviews and screening of existing merchants and transactions. |
| Transaction Screening | Automatically screen transactions in real-time against sanctions lists. |
| Alerts & Escalation | Any positive match or potential hit is escalated to the Compliance & Risk Team for review and further action. |
5. Roles & Responsibilities
Bayarcash assigns clear responsibilities across compliance, operations, and management to ensure effective sanctions screening and regulatory adherence.
| Role | Responsibility |
|---|---|
| Compliance & Risk Team | Maintain sanctions lists, review alerts, and report to authorities. |
| Operations & Frontline Staff | Ensure merchant and transaction data is screened as part of onboarding and transaction processing. |
| Management | Provide oversight and ensure resources for effective sanctions screening. |
6. Record Keeping
All screening results, alerts, and actions taken must be securely stored and retained according to Bayarcash’s Record Retention Policy.
7. Review of Policy
This policy will be reviewed at least annually or when regulatory requirements change to ensure ongoing compliance.