The Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy (“Policy”) is the policy of Google Pay Brasil Instituição de Pagamento Ltda. (“GPayBR” or “The Entity”) to maintain a risk-based Anti-Money Laundering (AML) / Counter Terrorist Financing (CTF) program that is (i) reasonably designed to prevent such entity from being used to facilitate money laundering and the financing of terrorist activities, and (ii) manage compliance with sanctions screening requirements and related legal obligations.
GPayBR maintains the required money transmission license and is subject to examination and regulatory oversight by the relevant national authorities as required by law.
Google Pay Brasil Instituição de Pagamento Ltda. has implemented written policies and procedures to comply with the laws and regulations applicable to its business. In addition to implementing / performing due diligence, monitoring, screening and reporting for anti-money laundering, counter terrorist financing and sanctions compliance purposes, as required by applicable law and as necessary in accordance with its license and a risk assessment of its business, to ensure there is appropriate knowledge of its customers and transaction activity. As part of its transaction monitoring program, the GPayBR entity maintains processes to establish alerts for suspicious transactions and report said transactions to law enforcement authorities.
The Entity has undergone an AML review performed by an internal and / or external third party (e.g., independent internal audit function) within the last two years.
GPayBR has no reason to believe that it maintains accounts for or provides products or services to, for the benefit of, or at the direction or order of individuals or entities appearing on screening lists produced by relevant authorities (e.g., in the US, OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or entities owned or controlled by any of the foregoing).
The Entity maintains relevant training standards as required by applicable laws and regulations and maintains robust governance programs including but not limited to the formal designation of a compliance officer or the local equivalent, internal audit programs, and information sharing with its Board of Directors and senior management.
Google Pay Brasil Instituição de Pagamento Ltda.