Anti-MoneyLaundering

What we're committed to

Xtopay moves money for businesses, so it could be misused to hide where money came from or to pay for crime. We won't let it be. We follow the Anti-Money Laundering Act, 2020 (Act 1044), the rules of the Bank of Ghana and the Financial Intelligence Centre, and the rules of our payment partner.

The person responsible for this at Sendexa Limited (the anti-money laundering reporting officer), and that the policy is reviewed every year.

Knowing who we work with

Before a business can be paid out, we check:

• the business: its registered name, its number with the Registrar-General, its Tax Identification Number, its address, and what it sells;
• the owner: their Ghana Card, matched against the National Identification Authority's records, and a selfie, matched against the card, through Sendexa Verify;
• where the money goes: the registered name of every payout account, from the network or bank, and whether it belongs to the business or its owner; and
• whether we can serve it at all, against our Acceptable Use Policy and the sanctions lists of the United Nations and the Government of Ghana.

For businesses that carry more risk (such as those our Acceptable Use Policy lists as needing approval), or that take larger amounts, we ask for more: licences, who owns and runs the business, and where its money comes from.

Watching how money moves

Checks at the start aren't enough, so we keep watching. Our systems and our staff look for payments, payouts and transfers that don't fit a business: sudden jumps in amounts, many small payments from the same people, money paid in and straight out again, or payments that don't match what the business says it sells.

Limits help too. Sending money is off until a business's owner switches it on, each business has a limit per transfer and per day, and a new payout account waits 24 hours before it's paid.

When something looks wrong

We may:

• ask the business to explain a payment, and for evidence;
• hold its payouts while we look into it;
• suspend or close its account; and
• report what we've found to the Financial Intelligence Centre or other authorities.

The law doesn't allow us to tell a business that we've reported it, so sometimes we can't explain a hold or a closure.

Keeping records

We keep the records of every check, payment, payout and transfer for at least 5 years after a business's account closes, as the law requires, and give them to the authorities when they lawfully ask.

Your part

As a business using Xtopay, you agree to:

• give us true details, and tell us when they change;
• answer our questions about payments promptly and honestly;
• take payments only for your own business; and
• never use Xtopay to move money whose source you can't explain.

If you know or suspect that Xtopay is being used for money laundering or fraud, tell us at complaints@xtopay.co.