Merchant Due Diligence (MDD) Policy

1. Introduction

FinTEM is committed to maintaining the highest standards of integrity within the global payment ecosystem. Our Merchant Due Diligence (MDD) policy ensures that we only provide technical orchestration services to legitimate, law-abiding businesses. This process is designed to prevent financial crimes, including money laundering, terrorist financing, and fraud.

2. The “Technical Gateway” Principle

As a technical infrastructure provider, FinTEM does not hold or process funds directly. However, we operate a mandatory “Gatekeeper” protocol. Technical connectivity is only granted to Merchants who meet our internal risk criteria and have successfully passed the onboarding requirements of our licensed Financial Partners (PSPs/Banks).

3. Mandatory KYB (Know Your Business) Requirements

Before any Merchant is granted access to the FinTEM production API, they must undergo a rigorous KYB process, which includes the collection and verification of:

3.1. Corporate Identity: Certified copies of Incorporation Certificates, Articles of Association, and Tax Registration.
3.2. Ultimate Beneficial Ownership (UBO): Identification and verification of all natural persons who own or control 25% or more of the legal entity.
3.3. Operational Licensing: Valid and verifiable proof of industry-specific licenses (e.g., Forex, iGaming, E-commerce) issued by competent regulatory authorities.
3.4. Website Compliance: All Merchant websites must display clear Terms of Service, Privacy Policies, Refund Policies, and physical contact information.

4. Risk-Based Approach (RBA)

We categorize Merchants based on their industry, transaction volume, and geographic location (e.g., CIS, Africa, Middle East).

4.1. High-Risk Industries: Merchants in sectors such as Forex, Gaming, and High-Volume E-commerce are subject to Enhanced Due Diligence (EDD), including regular reviews of their processing history and regulatory standing.
4.2. Sanctions Screening: All entities and UBOs are screened against global sanctions lists, including OFAC, UN, EU, and UK consolidated lists. FinTEM maintains a zero-tolerance policy toward sanctioned individuals or jurisdictions.

5. Continuous Monitoring

MDD is not a one-time event. FinTEM’s compliance team performs ongoing monitoring of:

5.1. Velocity Spikes: Unusual changes in transaction volume or patterns that may indicate a shift in business model or potential fraud.
5.2. Chargeback Ratios: Excessive chargeback or refund rates may trigger an internal review and potential suspension of technical services.
5.3. License Expiry: We periodically verify that all Merchant licenses remain active and in good standing.

6. Cooperation with Financial Institutions

FinTEM shares its MDD findings and metadata with upstream licensed Financial Partners to ensure a unified compliance front. We act in full cooperation with law enforcement agencies (e.g., MASAK, FinCEN) and will disclose Merchant data if a legal breach is identified.

7. Right to Refuse Service

FinTEM reserves the absolute right to refuse technical connectivity or terminate existing services for any Merchant that fails to meet our MDD standards, provides falsified documentation, or operates in a manner that poses a reputational risk to our platform.