Anti-Money Laundering, Fraud Prevention, and Customer Protection Policy

AYDAPAY Anti-Money Laundering, Fraud Prevention, and Customer Protection Policy

(Republic of Poland / European Union)

Company Name: AYDAPAY spółka z ograniczoną odpowiedzialnością
Country of Incorporation: Poland
Customer Support Email: help@aydapay.com
Customer Support: In-app chat

First Issue Date: 01 January 2025
Last Update: 09 February 2026

1. Purpose and Scope

This Policy aims to set out the framework adopted by AYDAPAY with respect to:

Anti-Money Laundering (AML),

Counter-Terrorist Financing (CTF),

Fraud prevention and financial crime mitigation, and

Customer protection and risk awareness.

This Policy applies to all customers, users, and transactions carried out through:

the website,

the mobile application, or

any other channels authorised by AYDAPAY.

This Policy forms an integral part of AYDAPAY’s Terms and Conditions and Privacy Policy.

2. Legal and Regulatory Framework

AYDAPAY operates in accordance with applicable laws and regulations in Poland and the European Union, including but not limited to:

EU Anti-Money Laundering Directives (AMLD),

The Polish Act on Counteracting Money Laundering and Terrorist Financing
(Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu),

Consumer protection laws, and

Guidelines, recommendations, and instructions issued by competent supervisory authorities.

Money laundering, terrorist financing, and fraud are serious criminal offences that threaten the integrity and stability of the financial system.

3. Risk-Based Approach

AYDAPAY applies a risk-based approach proportionate to:

the nature, scale, and complexity of its business activities,

the type of services and products offered,

customer profiles and behavioural patterns,

the geographic scope of transactions, and

relationships with third parties or correspondent banking partners.

Risk assessments are reviewed and updated periodically to reflect regulatory developments and emerging fraud typologies.

4. Principle of Shared Responsibility

Customer protection and fraud prevention rely on a shared responsibility:

AYDAPAY commits to implementing reasonable technical and organisational controls; and

customers are required to act with due care, provide accurate information, and avoid responding to pressure, deception, or manipulation.

No financial system can prevent all forms of fraud, particularly those involving social engineering or human error.

5. Customer Due Diligence (KYC / CDD)

AYDAPAY performs customer identification and verification procedures prior to and throughout the business relationship, which may include, as appropriate:

verification of personal identity,

identification of the beneficial owner where applicable,

determination of the purpose of the transaction and source of funds,

ongoing monitoring to detect unusual or suspicious patterns, and

application of Enhanced Due Diligence (EDD) in higher-risk cases.

5.1 Examples of Required Data and Documentation

Proof of identity (passport / national ID / residence permit),

Proof of address,

Contact details,

Information relating to the transaction or financial activity.

AYDAPAY reserves the right to request additional documentation at any time.
Failure to cooperate may result in delays, refusal, suspension, or termination of services.

6. Fraud Prevention and Early Detection

AYDAPAY implements appropriate measures to detect and prevent fraud, including:

transaction monitoring and behavioural analysis,

internal controls and segregation of duties,

escalation and internal review procedures, and

staff training on fraud risks and indicators.

Fraud risks include, but are not limited to:

phishing and scam communications,

impersonation of official entities,

romance and emotional fraud,

third-party coercion or pressure on customers, and

misuse of login credentials or payment instruments.

7. Customer Obligations

Customers are required to:

provide accurate and complete information,

verify beneficiary details before confirming any transaction,

safeguard passwords and authentication codes,

refrain from sharing personal or security credentials with any third party, and

report any suspicious activity immediately.

Providing false information or forged documents constitutes misuse of the service and may be reported to competent authorities.

8. Reporting of Suspicious Transactions

AYDAPAY is legally required to report suspicious activities to the competent authorities in accordance with applicable laws.

Customers must not be informed of the existence of a suspicious activity report
(prohibition of tipping-off).

9. Prohibited Activities and Uses

AYDAPAY services must not be used for:

any unlawful or fraudulent activity,

money laundering or terrorist financing,

circumvention of sanctions or laws,

unlicensed financial activities,

fraudulent or pyramid schemes, or

dealings with sanctioned persons, entities, or jurisdictions.

AYDAPAY reserves the right to refuse any activity that exceeds its acceptable risk threshold.

10. Right to Refuse, Suspend, or Terminate

AYDAPAY reserves the right, without prior notice where permitted by law, to:

refuse to execute a transaction,

delay execution for verification purposes, or

suspend or terminate a customer account,

where there is a reasonable suspicion of:

money laundering,

terrorist financing,

fraud or other financial crime, or

breaches of applicable laws or internal policies.

11. Record-Keeping and Confidentiality

AYDAPAY maintains records of:

customer data,

transactions, and

compliance documentation,

generally for a minimum of five (5) years following the end of the business relationship or execution of the transaction, as required by law.

All data is treated as strictly confidential and is disclosed only to competent authorities where legally required.

12. Limitation of Liability

To the extent permitted by law, AYDAPAY shall not be liable for losses arising from:

customer negligence or errors,

incorrect data entry,

sharing of access credentials, or

fraud resulting from deception outside AYDAPAY’s reasonable control.

This does not affect any non-waivable statutory rights.

13. Customer Acknowledgement

By using AYDAPAY services, the customer acknowledges that they:

have read and understood this Policy,

have provided accurate information,

understand that compliance procedures are mandatory, and

accept responsibility for any loss resulting from their negligence or improper conduct.

14. Review and Updates

This Policy is subject to periodic review to reflect:

legislative and regulatory changes,

evolving financial crime risks, and

supervisory guidance.

The most recent version is always available via the website and mobile application.