As a regulated international payment company, transaction monitoring is an important component of RZForex's anti-money laundering and anti-financial crime framework.
The purpose of our transaction monitoring functionality and processes is to:
- Identify and prevent transactions related to sanctioned individuals, entities, or countries.
- Identify transactions and behavioural patterns that may be associated with money laundering, terrorist financing, or other financial crimes.
- Investigate transactions and behavioural patterns to ensure compliance with our understanding of the customer, their business, and risk tolerance.
- Make decisions on transactions and potential suspicious behaviours that trigger manual review.
We conduct real-time screening by scrutinizing transaction fields related to customers and transactions. Our banking partners may request further information for individual transactions that have not been executed yet. The system automatically performs screening, but if the screening fails, it generates an alert for manual review. Our compliance experts review these alerts manually. Transactions are either manually approved, manually rejected, or temporarily held for further investigation. Certain activities of entities may trigger alerts, indicating that the transaction behavior of these entities may require investigation by compliance experts. Alerts undergo review, and in some cases, we may conduct enhanced due diligence on the entities or even terminate the business relationship.
Our compliance team relies on our understanding of relevant entities, past transactions, behavior of other customers in the same business area, and information in our records to make judgments. However, we can only see a portion of entity activities. We may request additional information from customers to assist our team in timely resolution of alerts.
When alerts occur, we investigate the following aspects of the transactions:
- Who is the sender?
- What is the source of funds for the sender? If applicable, who are their customers?
- Who is the recipient?
- What is the relationship between the sender and recipient?
- What is the purpose of the transaction? Considering the relationship between the sender and recipient, is the transaction purpose legitimate?
- Does the transaction align with the transaction history and information of the sender and recipient?
We may request the following information:
- Identity proof: e.g., passport, driver's license, identity card
- Address proof: e.g., utility bills, bank statements, mortgage loan statements
- Company registration documents: e.g., registered name, trade name, address
- Business evidence: e.g., sales invoices, product lists/brochures, transportation documents (bills of lading, airway bills), business contracts/agreements
- Additional information on the relationship between the sender and recipient
- Director/shareholder register (signing dates, company letterhead), and employment history of these directors/shareholders.
- Source of funds: e.g., bank statements, payslips, audited financial statements of the company, loan contracts.
- Source of wealth: e.g., wills, probate orders, proof of share sales, asset and income declarations, dividend documentation
- Real estate purchase/sale agreements (including price, location, detailed information of agents/lawyers)
- Online activity links of the sender/recipient (if not found through our own searches): e.g., LinkedIn profiles, listings on e-commerce platforms.
The following types of transactions or entities may undergo stricter scrutiny and require additional information:
- Transactions from/to countries with a higher potential risk of financial crime
- Transactions involving senders/recipients with almost no presence on public networks.
- Companies with high transaction amounts or no physical goods being shipped (e.g., marketing, consulting) may be asked to provide director/shareholder information.
To help us resolve alerts promptly, please note the following:
- Generally, submitted documents should be dated within the last 3 months.
- Generally, only PDF files are accepted.
- We do not accept files such as Word, Excel, or screenshots (e.g., bank statements, email records, WhatsApp conversations).
Compliance with these guidelines will help expedite the resolution of alerts and ensure the security and integrity of our platform.