AML / CFT Policy

Kaadxpay Financial Solutions Pty. Ltd. has zero tolerance for money laundering, terrorism financing, sanctions evasion, fraud and proliferation financing. As an Approval-in-Principle holder of a Labuan Payment System Operator licence, we maintain a comprehensive AML/CFT programme designed to detect, deter and disrupt the misuse of our payment infrastructure.

This page is the public summary of our AML/CFT framework. The full internal manual (~120 pages) is filed with the Labuan Financial Services Authority (LFSA), signed by the Money Laundering Reporting Officer (MLRO) and the Compliance Officer, and is available to banking partners and regulators under appropriate confidentiality terms.

• Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), Malaysia.
• Strategic Trade Act 2010, Malaysia (proliferation financing).
• Labuan Financial Services and Securities Act 2010 (LFSSA) Section 171 et seq.
• LFSA Guidelines on Anti-Money Laundering, Counter-Financing of Terrorism and Targeted Financial Sanctions for Designated Non-Financial Businesses and Professions and Other Reporting Institutions.
• Bank Negara Malaysia AML/CFT Policy Documents (sectoral).
• Financial Action Task Force (FATF) 40 Recommendations, in particular Recs. 1, 5, 6, 10–22 and the Travel Rule (Rec. 16).
• United Nations, EU, OFAC, UK and Malaysia targeted financial sanctions lists.

AML/CFT is owned at board level. The Board of Directors approves the AML/CFT policy at least annually and reviews quarterly compliance reports. Day-to-day execution sits with three independent functions:

• Compliance Officer (1st line) — programme design, training, regulatory liaison, internal advice. Reports to the CEO with dotted line to the Audit Committee.
• Money Laundering Reporting Officer / MLRO (2nd line) — Suspicious Transaction Report (STR) and Cash Threshold Report (CTR) submission, sanctions screening oversight, transaction-monitoring rule sign-off. MLRO has direct, protected reporting line to the Board and to LFSA.
• Internal Audit (3rd line) — independent annual audit of the AML/CFT programme; findings reported to the Audit Committee and LFSA on request.

The MLRO is appointed in writing, has direct access to all relevant data and systems, and cannot be dismissed without LFSA notification. Whistle-blower channels (compliance@kaadxpay.com) are available to all staff and external counterparties; reports are handled under our Whistle-Blower Procedure with strict confidentiality and anti-retaliation safeguards.

We apply a risk-based approach as required by FATF Recommendation 1. A documented Enterprise-Wide Risk Assessment (EWRA) is reviewed at least annually and after any material change in business model, geography or product. The EWRA classifies inherent risk along four axes — customer, product, geography and channel — and informs the calibration of all downstream controls.

We do not service retail consumers. Our customers are businesses and we apply tiered Customer Due Diligence:

No anonymous accounts, no shell-bank correspondents, no pass-through accounts, and no business relationship is entered into where beneficial ownership cannot be reasonably established.

• All counterparties (merchants, partners, beneficial owners, directors, payout beneficiaries) are screened at onboarding and continuously thereafter against UN, EU, OFAC, UK HMT and Malaysia consolidated lists, plus politically-exposed persons (PEP) and adverse-media databases.
• List updates are pulled within 24 hours of publication and re-screened across the full customer base.
• Any positive match results in immediate freezing of the relationship pending MLRO investigation and, where required, an STR / Targeted Financial Sanctions report to the Financial Intelligence Unit (FIU) of Bank Negara Malaysia.
• Sanctions screening is also applied to inbound and outbound payment counterparties at the transaction level.

All transactions are monitored in real time and post-transaction by an automated rule engine. Rules cover:

• Velocity, layering and structuring patterns;
• Geographic risk (high-risk jurisdiction routing);
• Behavioural deviations from established merchant baselines;
• Round-amount and threshold-avoidance patterns;
• Sanctions and PEP-list real-time screening;
• Time-of-day and channel anomalies.

Alerts are triaged within agreed SLAs by trained analysts. Where a suspicion of money laundering, terrorism financing or proliferation financing arises, an STR is filed with the FIU within statutory deadlines (typically as soon as possible and in any event within 5 business days under AMLA). Cash Threshold Reports (CTR) are filed where applicable. Tipping-off is strictly prohibited.

For cross-border wire transfers above the de-minimis threshold, originator and beneficiary information is collected, transmitted with the payment and retained for at least five years. Incoming transfers with missing or incomplete originator information are rejected, suspended or treated under the risk-based approach for further enquiry, depending on the deficiency.

AMLA requires retention of all customer records and transaction data for at least six years from the date of the relevant transaction or termination of the business relationship, whichever is later. Kaadxpay's policy is six years; tax records are retained seven years per Malaysia tax law. All records are accessible to LFSA and law-enforcement authorities upon proper legal request.

• All staff complete AML/CFT induction within 30 days of joining, plus annual refresher training tailored by role.
• High-touch roles (compliance, MLRO, sales, onboarding, customer support) receive deeper quarterly training.
• Training records are retained for six years and produced to LFSA on request.
• Independent assurance of training delivery is part of the annual Internal Audit programme.

Kaadxpay cooperates fully and promptly with LFSA, Bank Negara Malaysia, the FIU, law enforcement, and foreign counterparts acting through proper Mutual Legal Assistance channels. Production orders, freezing orders and information requests are handled by the MLRO in coordination with external counsel where appropriate.

For AML/CFT enquiries, banking-partner due-diligence requests, or to file an externally-sourced concern, please contact compliance@kaadxpay.com. Suspicious-activity intelligence specifically intended for the MLRO can be marked "Attn: MLRO — Confidential" and we will route it accordingly.