AML / CFT Policy

SPECTRA provides payment acceptance, payout and settlement services to businesses. We are committed to preventing our infrastructure from being used for money laundering, terrorist financing, sanctions evasion, fraud or any other financial crime. This policy summarises the principles and controls we apply.

1. Scope

This policy applies to all merchants, partners and counterparties connected to SPECTRA, to all products we operate (acceptance, payouts, local payment methods, fiat and crypto settlement) and to all employees and contractors involved in onboarding, operations and monitoring.

2. Risk-based approach

We assess each merchant and each transaction flow using a risk-based approach that considers the industry, jurisdictions involved, expected volumes, payment methods, ownership structure and transaction behaviour. The level of due diligence and monitoring is proportionate to the assessed risk.

3. Know Your Business (KYB) and due diligence

• Verification of the legal entity: registration documents, registered address and legal status.
• Identification and verification of directors and ultimate beneficial owners (UBO) holding 25% or more.
• Assessment of the business model, website, traffic sources and licences where required by the vertical.
• Enhanced due diligence for higher-risk merchants, jurisdictions or ownership structures, including source-of-funds information.
• Periodic reviews and re-verification when material changes occur.

4. Sanctions and PEP screening

Merchants, their owners and key counterparties are screened against applicable international sanctions lists and politically exposed person (PEP) databases at onboarding and on an ongoing basis. Relationships with sanctioned parties are not established or are terminated.

5. Transaction monitoring

Payment flows are monitored for patterns that may indicate money laundering, fraud or misuse — including unusual volumes, velocity, structuring, mismatches between declared and actual activity, and payouts to unrelated third parties. Alerts are reviewed by our compliance function and may result in additional requests for information, holds or termination.

6. Prohibited activities

We do not provide services to businesses involved in unlawful activities, including but not limited to: unlicensed financial services, sale of illegal goods, child exploitation material, weapons trafficking, terrorist financing, sanctions evasion or deceptive practices. Verticals that require licensing are accepted only where appropriate licensing is confirmed.

7. Record keeping and reporting

Onboarding records, transaction data and monitoring outcomes are retained for the period required by applicable law (at least five years). Where required, suspicious activity is reported to the competent authorities, and we cooperate with lawful requests from regulators and law enforcement.

8. Governance and training

A designated compliance officer is responsible for this policy, its implementation and periodic review. Staff involved in onboarding and operations receive regular AML/CFT training.