Papaya Limited (referred to as ‘Papaya’) is licensed by the Malta Financial Services Authority and is licensed in terms of the Financial Institutions Act as an e-money institution and payment service provider. The activities are defined under the second and third schedules of the Financial Institutions Act. The Company is therefore bound and obliged to implement and comply with the Prevention of Money Laundering and Financing of Terrorism as defined by the Banking Act of Malta.
In Malta, Money laundering, together with funding of terrorism, is extensively defined in a number of Acts and Regulations, which include the following: FIAU Procedure and Guidance implementing the provisions of PMLFTR (Malta), FIAU Implementing Procedures, Issued 20th May 2011 (Malta), Prevention of Money Laundering ActCap. 373 (Malta), Criminal Code (Malta), Prevention of Money Laundering and Funding of Terrorism Regulations (Malta), Financial Action Task Force Recommendations (40+9) (FATF-GAFI), The 3rd EU Directive on Money Laundering and Financing of Terrorism. The above Regulation and Legislation will be used as a governing source to outline the framework and strategic position of AML/CFT procedures that are relevant to the business of the Company. To that extent, constant reference will be made to the FIAU Guidance in specific so as to ensure a transparent and consistent approach throughout.
The funding of terrorist activity, terrorist organisations or individual terrorists may take place through funds deriving from a legitimate source or from a combination of lawful and unlawful sources. The Company acknowledges the risks and threats in connection with its activities and has produced these policies and procedures in order to set out their strategic position to ensure compliance within all areas of operation.
Every employee is required to act in furtherance of this policy statement to protect the Company from exploitation by money launderers or terrorists.
As a minimum, Papaya Ltd will:
– Raise awareness on money laundering issues.
– Assist law agencies and authorities to trace, seize, and confiscate the proceed of criminal activities.
– Introduce a Know-Your-Customer Policy (KYC).
– Appoint a designated Money Laundering Reporting Officer (MLRO). The MLRO is to report any suspicious transactions to the Financial Intelligence Analysis Unit and should copy the MFSA, Malta Financial Services Authority.
– Exercise reasonable measures to obtain information about the true identity of the persons on whose behalf a transaction is made.
– Pay special attention to all complex, unusually large transactions.
– Adopt economic, administrative, self-regulatory and other measures which can be taken to create an effective shield against money laundering.
– Employ different ways and means of monitoring and tracking clients’ unusual and suspicious transactions. Information from independent sources: clients’ contacts.
– Train staff accordingly.
– Employ proper care in the hiring of new staff.
KYC (Know Your Customer) Policy
The Papaya Limited using this website’s online facilities, data subjects may be required to provide their personal data for the purposes of fraud prevention and anti-money laundering controls.
The Papaya Limited customers sensible information will be:
1. processed fairly and lawfully;
2. processed in accordance with good practice;
3. collected for specific, explicitly stated and legitimate purposes.
4. not processed for any purpose that is incompatible with that for which the information is collected.
5. processed no more than is necessary having regard to the purposes of the processing.
6. not kept for a period longer than is necessary, having regard to the purposes for which they are processed.
The Papaya Limited reserves the right to disclose personal data to authorities when The Papaya Limited has reasonable grounds to suspect irregularities that involve a Customer Account.