Mrpacho maintains a comprehensive programme to prevent money laundering and the funding of terrorism. This policy governs the collection, verification, maintenance, and review of customer information in connection with the services offered on the Mrpacho platform, and integrates with the Terms of Service. It is a live document and, where required by law or risk assessment, will be updated with approval by the designated governance bodies.
This policy applies to all customers, products, payment methods, and account activities on the Mrpacho platform. Its objectives are to (a) verify user identities and assess risks prior to and during the customer relationship, (b) establish and maintain an ongoing understanding of each customer’s profile and intended activity, (c) detect and report suspicious activity in accordance with applicable law, and (d) protect the integrity of the platform and its users.
The Mrpacho board holds ultimate responsibility for AML/CTF compliance. A Money Laundering Reporting Officer (MLRO) is appointed to oversee day‑to‑day implementation, monitor procedures, and liaise with authorities. The MLRO retains independence and adequate resources to perform these duties, and is responsible for coordinating policy updates, KYC and due diligence measures, transaction monitoring, and training programs.
Mrpacho applies a risk‑based approach to customer due diligence. All users must be registered and provide documentation sufficient to verify identity and age before full platform access is granted, and on an ongoing basis as required by risk assessment.
EDD applies to customers or activities identified as higher risk. Triggers include, but are not limited to, customers with elevated political exposure, customers from or transacting with high‑risk jurisdictions, unusually large or complex patterns, or other red flags. EDD measures may include collecting additional verification documents, confirming source of funds and source of wealth, more frequent or intensified monitoring, and, where necessary, approval from senior management to establish or continue the business relationship.
Mrpacho will obtain and assess the source of funds (SoF) and source of wealth (SoW) for each customer, particularly where transactions are large, originate from high‑risk jurisdictions, or trigger enhanced due diligence. Acceptable SoF/SoW evidence includes, as applicable, bank statements, payslips, tax records, or other documents that demonstrate legitimate origin of funds and sustainable means behind the customer’s activity.
Ongoing monitoring is risk‑based and designed to identify anomalous or suspicious activity over time. Customer information and documentation must be kept up to date, with periodic reviews especially for higher‑risk profiles. Monitoring covers transaction patterns, payment methods, and platform activity to confirm consistency with the customer’s profile and stated purpose.
Mrpacho reserves the right to refuse service, or to suspend or terminate an existing account, where there is non‑compliance with KYC/EDD procedures, suspicion of deception or identity misrepresentation, or where the customer’s position cannot be reasonably verified. Factors include failed verification, false or forged documents, misrepresentation of location, sanctions exposure, PEP status with unmitigable risk, or insufficient SoF/SoW.
All customers and counterparties are screened against relevant sanctions lists and PEP databases. A customer identified as a PEP or associated with a high‑risk jurisdiction may require enhanced scrutiny. Red flags include inconsistent information, use of multiple accounts without legitimate reason, high‑risk payment methods, rapid deposit and withdrawal activity with minimal gameplay, and requests to transact with third parties or through anonymous channels.
Mrpacho employs a combination of automated and manual monitoring to detect suspicious activity. Key controls include:
Mrpacho will retain records related to AML/CTF activities for a minimum period of five (5) years from the end of the customer relationship or the date of the last transaction, whichever is later. Records include identification documents, verification data, transaction details, communications regarding AML/CTF matters, internal suspicious activity investigations, and training records. Records are stored securely and are accessible to competent authorities on legitimate request.
Any employee who suspects potential ML/TF activity must promptly report concerns to the MLRO. The MLRO will investigate and, if warranted, file a Suspicious Activity Report (SAR) with the competent financial intelligence unit or relevant authority without delay, in accordance with applicable law. No employee or customer will be tipped off that an investigation or reporting has occurred, except as legally permitted. Mrpacho will cooperate fully with law enforcement and regulatory authorities within legal constraints.
Mrpacho provides ongoing AML/CTF training to all relevant personnel, covering applicable laws, internal policies, identification of red flags, and procedures for reporting suspicious activity. Training is reviewed periodically and updated to reflect changes in regulation and risk.
Personal data collected in relation to KYC/AML activities is processed in accordance with applicable privacy laws and the platform’s privacy framework. Data is retained and secured to protect individuals’ information and is processed solely for purposes consistent with this policy, with access limited to authorized personnel and regulatory obligations.
The MLRO and the compliance function are responsible for enforcing this Policy and answering questions about KYC/AML requirements. Questions or requests for information should be directed through the platform’s official support channels or compliance contact as published within the Terms of Service.