Paystar Remittance Suite

Anti-Money Laundering
Know-Your-Customer
Introduction
Financial Services Organizations risk heavy monetary fines and other punitive
action for non-compliance with regulatory requirements that are aimed at
detecting and deterring financial crime. Translink has developed our solution the
Paystar Remittance Suite to deliver a wall of protection focused on Anti-Money
Laundering (AML).

Almost every country in the world has issued legislation and or regulatory
requirements that impose minimum standards on organizations in the financial
services industry demanding that appropriate steps be put in place to both detect
and deter financial crime, specifically money laundering and terrorist financing.
Organizations can rest assured that Translink has taken the appropriate steps to
develop these requirements into our solutions and that we are continually
investing in tightening the security and reporting capabilities of our solution.

www.translink-co.com
Anti-Money Laundering
Historical events have precipitated a change in the way governments and
industry regulators treat money laundering and suspicious financial activity.
Financial institutions are the primary target for tightening requirements to deter
such criminal activities. Organizations who fail to meet these compliance
requirements are facing tough penalties including hefty fines, and cease and
desist orders.

Our Anti-Money Laundering Process Basics

Our process has a number of basic steps;

1. An anti-money laundering program which includes; policies and

procedures, a compliance officer, training and education for employees,
and an internal audit process to ensure program effectiveness.

2. Implementation of a customer identification program that verifies the

identity of our customers using reliable source documents and data,
identifying the beneficial owner and creates a business and risk profile
associated with that individual. Customer identities are checked against
OFAC, sanction lists and watch lists, which can be integrated with a
financial institution’s policies.

3. Monitoring activity, restricting transactions, and identifying suspicious

transactions that are outside the risk profile parameters either set by
legislation, in accordance to Central Bank or within the institutions own
risk assessment policies.

4. Reporting suspicious transactions to the appropriate Central Banks

involved in the transaction process to provide intelligence for the
investigation into the details surrounding the transaction, and document
the resolution for potential action.

5. Provide to the financial institution any documentary and non-documentary

evidence upon request to determine customer identification information
and suspicious transaction details.

www.translink-co.com
Using Our AML Technology to Reduce Costs and
Improve Efficiencies
Translink has invested a great deal of time in implementing AML services for
our client financial institutions. Our solution gives an organization an
opportunity to reduce manual and redundant tasks, and improve compliance.
By providing the right tools an organization can stream-line the capture,
storage and retrieval of customer identification content and transaction data.

The following AML functions reside in and are set as processes within the
solution:

1) Each customer is issued a card or an account according to the

requirements of their Central Bank(s) and all Know-Your-Customer
(KYC) documentation is available to the bank for review and audit (see
attached – application form) for ten (10) years. The system can deliver
the appropriate documentation for each issuance to the bank upon
request.

2) Only registered customers of the system can receive and send funds
to and from each other creating a known closed-loop. Thus, giving the
bank audit capabilities on every transaction originated and received by
our customers. Remitters cannot send funds to beneficiaries outside
the system without proper registration and KYC documentation upon
issuance of a card or an account.

3) The system can restrict and/or report on the issuance of a card or an

account based on OFAC, sanction lists and/or watch lists.

4) The system by default restricts the issuance of more than one card or
an account to the same recipient based on the following parameters:
a. Name
b. Passport/National ID
c. Address
d. By the end of the 2nd Qtr. 2009 biometrics technology will be
available (as an option to our clients) to verify, identify and securely
restrict the system from issuing multiple cards and/or accounts.
i. During sign up our biometrics technology records the
fingerprint of the applicant and uses this information for
matching to potential multiple issuances.
ii. From this data we will introduce a new security layered
payment, ATM and authentication system based on the data
captured during this process.

www.translink-co.com
5) Velocity – the system restricts in real-time the capability of a single
remitter to send more than a specified amount designated by the
Central Bank or an amount that we designate that falls under these
guidelines in one (1) day and over a rolling thirty (30) day period. The
remitter cannot send more than the Velocity limited amounts even if
the transactions are made to multiple beneficiaries.

6) The system restricts overage of loading funds set by the guidelines of

the Central Bank and restricts the sending of funds (Velocity) by the
guidelines of both the sending Central Bank and the receiving Central
Bank. The system checks the balance of the card before each
transaction. When sending funds the system makes sure that the funds
are available, and when receiving funds it verifies that the card will not
exceed its maximum balance.

7) The system is fully capable of implementing any other AML

requirements set by the Organization, but Translink would like to clarify
these two points:

a. The remitters information is verified via the following methods:

i. Before a transaction is sent or processed the remitter is
required to verify his/her PIN through a secure method, this
PIN can be verified against the CMS or verified against the
virtual (secondary) PIN issued by the system. This applies to
a mobile, online, IVR and a live customer service originated
transaction. Mobile and landline numbers are registered to a
specific account holder and transactions from that device are
verified against the PIN and customer identification
information.
ii. Upon request from the Organization, the system is capable
of passing back the confirmation receipt of the delivery of
funds to the correct beneficiary from the receiving bank. As
such this confirmation is a guarantee from the receiving bank
and part of the audit trail.

www.translink-co.com
Conclusion
The Paystar Remittance Suite provides the appropriate support for all Anti-
Money Laundering compliance, with a set of processes and technology.

Translink recognizes the adverse impact of money laundering and terrorist

financing could have on your organization. Financial crime not only negatively
reflects on individuals, the institution, and the commercial sector, but on national
and international economic systems as a whole. Naturally, financial institutions
are the primary target for tightening the requirements to deter and detect financial
crime, including fraud, computer crime, identity theft, money laundering, and
terrorist financing. Organizations face a number of risk factors associated with
these illegal activities including hard costs such as financial loss, and soft costs
associated with reputation and customer attrition. The Paystar Remittance Suite
supports Anti-Money Laundering compliance and will work with you to minimize
those risks while reducing the overall costs of BSA/AML compliance.

www.translink-co.com