Anti-Money Laundering Policy

RevLinkers LTD, registered in England and Wales (Company No. 16956390), is committed to full compliance with the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).

We operate a zero-tolerance policy towards money laundering, the facilitation of tax evasion, bribery, corruption, and any form of financial crime.

This policy applies to:

• All directors, employees, and contractors of RevLinkers LTD
• All Partner Companies entering into a Partnership Agreement with RevLinkers
• All E-commerce Partners operating through our network
• Any third parties acting on behalf of RevLinkers or its partners in a payment processing capacity

We apply Customer Due Diligence (CDD) measures to all parties entering into a partnership with RevLinkers . This includes:

• Identity Verification: All partners must provide government-issued photo identification (passport or national identity card)
• Proof of Address: A utility bill, bank statement, or official document dated within 3 months
• Business Verification: For corporate partners, company registration documents, certificate of incorporation, and details of beneficial ownership (individuals owning 24% or more of the entity)
• Bank Account Verification: Evidence that payment accounts are held in the partner's name and domiciled in a compliant jurisdiction
• Source of Funds: Where required, partners may be asked to confirm the legitimate source of funds flowing through payment accounts

We reserve the right to conduct Enhanced Due Diligence (EDD) on partners presenting higher risk, including those from high-risk jurisdictions as defined by the Financial Action Task Force (FATF).

RevLinkers conducts risk assessments of its partnerships and operations. Factors considered include:

• The nature and purpose of the partnership arrangement
• The countries and jurisdictions involved in payment flows
• The types of products and services sold through linked payment accounts
• The volume and velocity of transactions processed
• Any adverse media, sanctions checks, or PEP (Politically Exposed Person) screenings

RevLinkers will not knowingly facilitate, and requires all partners not to engage in:

• Processing payments for illegal goods or services (including controlled substances, counterfeit products, or content that violates UK law)
• Layering or structuring transactions to disguise the origin of funds
• Processing payments through Stripe or other processors in violation of those processors' terms of service
• Using partnerships to evade tax obligations in any jurisdiction
• Engaging with sanctioned individuals, entities, or jurisdictions (as listed by OFSI, OFAC, or UN sanctions lists)

We monitor the activities of our partnerships for indicators of potential money laundering or financial crime, including:

• Unusual spikes in transaction volumes inconsistent with the stated business model
• High rates of chargebacks or refunds suggesting fraudulent activity
• Payments to or from sanctioned individuals, entities, or high-risk jurisdictions
• Requests to redirect payments to third-party accounts unrelated to the partnership
• Patterns of activity inconsistent with legitimate e-commerce operations

All employees, contractors, and partners of RevLinkers are required to:

• Report any knowledge or suspicion of money laundering or financial crime to RevLinkers ' designated compliance contact immediately
• Not "tip off" any person under investigation or suspected of financial crime
• Cooperate fully with any investigation or enquiry by the National Crime Agency (NCA), HMRC, or other relevant authorities

RevLinkers retains all KYC documentation, due diligence records, and transaction records for a minimum of 5 years from the end of the business relationship, in accordance with the Money Laundering Regulations 2017. Records are held securely and are available to competent authorities upon lawful request.

Any partner found to be in breach of this AML Policy or applicable money laundering legislation will:

• Have their partnership agreement terminated immediately
• Be reported to the relevant regulatory and law enforcement authorities
• Be held liable for any losses, fines, or penalties incurred by RevLinkers as a result of their non-compliance

RevLinkers ensures that all personnel involved in onboarding partners or overseeing payment operations receive regular training on anti-money laundering obligations, relevant legislation, and red flag indicators. This policy is reviewed at least annually or following significant changes to applicable legislation or our business model.

For AML-related enquiries, to report suspicious activity, or for compliance questions, please contact us:

RevLinkers LTD is registered in England and Wales. Company No. 16956390. This policy is governed by the laws of England and Wales.