Pay Well Wallet is a Payment gateway offering advanced credit card VISA and MASTERCARD processing for high risk merchants including gaming, gambling, FX crypto and many more.

Anti-Money Laundering (AML) Policy

General Provision

Pay Well Wallet (from now on – the company or Pay Well Wallet) is a provider of technical processing services.

The company shall conform to the local Acts’ requirements on Prevention of Money Laundering and Terrorism Financing and the requirements of other laws and regulations to the extent in which they relate to Pay Well Wallet’s operations.

The company shall strictly comply with the policies and procedures outlined in this document (hereafter – the policy).

Pay Well Wallet develops this policy and may introduce amendments and additions to it at its own volition and oversee compliance with its provisions and requirements.

The client shall read the Policy before accepting Pay Well Wallet’s Terms and Conditions. The client’s consent of the Terms and Conditions, as we as Clients’ making transactions in the Pay Well Wallet system after accepting the Terms and Conditions, shall signify the client’s acceptance of all the current version provisions of this Policy.

Compliance Officer

To oversee and execute the procedures contemplated in the Policy, Pay Well Wallet appoints a Compliance Officer.

The Compliance Officer is liable for the collection, analysis, and investigation of information on any suspicious actions and the practice of the company’s employees pertaining to the relevant procedures; the Merchant Services Officer shall determine the guidelines and rules for carrying out customers’ identification, reviewing and monitoring unusual transactions and technical features of the Pay Well Wallet’s implementation of this Policy.

Customer Identification Policy

For clients’ identification, Pay Well Wallet requests the following documents:

Know Your Customer Verification Procedure

Pay Well Wallet conducts the KYC (Know Your Customer) verification procedures to avoid the risk of being held liable and protect itself from a customer’s attempting to use the company to carry out illegal activities.

Pay Well Wallet evaluates customers’ transactions and collects and stocks data and essential facts pertaining to customers, potential clients, and their transactions as part of the KYC procedures.

After taking out the identification procedures pertaining to a client, Pay Well Wallet stores the info obtained in the client’s file. The company is under commitment to carry out the identification procedures related to a client once.

Pay Well Wallet is committed to protecting client’s rights and the confidentiality of their data. Pay Well Wallet collects personal information from the client only to the extent necessary to ensure Pay Well Wallet properly providing service to clients. Such personal information about clients and former clients may be disclosed to third party only a limited number of circumstances, under the applicable laws and agreements between Pay Well Wallet and the client.

Pay Well Wallet shall carefully maintain customer’s file, including the statement, transaction reports, receipts, notes, internal correspondence, and any other information related to the customer in electronic format for as long as may be required by the underwriting teams at the relevant acquiring banks/processors that customer makes use of.

Identification and Detection of Suspicious Activities

Any transaction that may be related to money laundering activities shall be considered to be suspicious activities.

Areas for determining that a specific transaction is suspicious may be the personal sights and experience of the Company’s employees and the information received or identified.

The Merchant Services Officer shall continuously observe and update the company’s systems to detect suspicious activities.

Following the applicable laws and international organizations’ requirements, the Company may, where appropriate and without the obligation of obtaining the Customer’s approval or informing the client, notify regulating and/or law enforcement agencies of any suspicious transactions.

Pay Well Wallet shall periodically refer to and consult the lists published by the local officials and international organizations that include lists of known terrorists or persons speculated of terrorist activities, terrorist organizations, high-risk countries, a limited list of countries subjected to the OFAC sanctions. These jurisdictions do not give a sufficient level of anti-money laundering procedures, and countries directed to sanctions to decide whether the Company’s Customer or potential Customer and/or such Customer’s country of jurisdiction is involved in the above lists.

Pay Well Wallet shall continuously conduct due diligence procedures pertaining to its Customers and scrutinize transactions carried out by them to ensure these transactions’ compatibility with Pay Well Wallet’s knowledge of its customers, their business and, when necessary, their source of funds.


To execute some of its business functions, Pay Well Wallet may use third-party service providers. Pay Well Wallet shall make an effort to determine, during the initial and ongoing due diligence process, to the extent possible whether there are any admitted investigation and filed lawsuits against any such third-party service providers. Pay Well Wallet shall also decide whether a third-party provider has obtained all the necessary licenses, permits, and approvals prior to establishing a business relationship with such a third-party service provider.

Concerning its staff, Pay Well Wallet shall carefully review all candidates for employment and determine whether a new employee’s activities fall in the category that is susceptible to money laundering activities. The Company has also developed and implements several personnel training programs on customer identification methods and the prevention of money laundering activities.

Civil and Criminal Penalties

Government authorities of various countries and, in some cases, international organizations may impose stiff civil and criminal penalties against any person that infringes the laws and guidelines referred to in paragraph 1.2 of the Policy. Such civil and criminal legal penalties may carry fines in the amount of up to hundreds of thousands or even millions of dollars. The term of criminal punishment may be many years in prison. Besides, government authorities may confiscate any property involved in criminal violation of these laws and ordinances, including firms, bank accounts, or any other assets associated with criminal offences.

Under certain conditions, companies may be considered criminally responsible for the actions of their employees. In this regard, our corporate customers’ employees need to have adequate knowledge in this sphere; it is also important that such Corporate Customers so crucial the compliance of their employees’ actions with the said laws and regulations.

Compliance Statement

The Corporate Client (the Corporate Client’s authorized employee) certifies that they have gone through and conceded this notice and that they (or their company) shall function in full compliance with the terms and standards described in the Policy and comply with all applicable laws and other ordinances and conditions governing its activities as a Corporate Customer.

The Corporate Client (the Corporate Client’s authorized employee) confirms that they are responsible for their actions following the effective laws in the field discussed in this Policy and shall bear responsibility pertaining to failure to comply with such laws.