This document is a structural template. Its wording has not been written or reviewed yet and does not form part of any agreement.
1.Purpose and scope
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- 1.1[Legal text to be provided by counsel]
- 1.2[Legal text to be provided by counsel]
2.Our role and our infrastructure partner's role
[Legal text to be provided by counsel]
- 2.1[Responsibilities of MWMCUBE BILLS PAYMENT SERVICE]
- 2.2[Responsibilities of the payment infrastructure provider]
3.Customer due diligence
[Legal text to be provided by counsel]
- 3.1[Identity information required and when]
- 3.2[Business customers and beneficial ownership]
- 3.3[Enhanced due diligence]
4.Beneficiary information
[Legal text to be provided by counsel]
- 4.1[Legal text to be provided by counsel]
- 4.2[Legal text to be provided by counsel]
5.Legitimate professional services and supporting documents
[Legal text to be provided by counsel]
- 5.1[Invoices, contracts and statements of work that may be requested]
6.Transaction monitoring
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7.Sanctions screening
[Legal text to be provided by counsel]
- 7.1[Legal text to be provided by counsel]
- 7.2[Legal text to be provided by counsel]
8.Customer-provided wallets and network checks
[Legal text to be provided by counsel]
9.Record keeping
[Legal text to be provided by counsel]
10.Reporting
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- 10.1[Reporting of suspicious activity to the relevant authorities]
11.Restricted jurisdictions
[Legal text to be provided by counsel]
- 11.1[Restricted jurisdictions]
12.Training and review
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13.Contact the compliance team
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- 13.1[Legal text to be provided by counsel]
- 13.2[Legal text to be provided by counsel]