Risk Appetite Statement

December 2023

Purpose and Scope

This document covers the risk appetite for the B4B Payments Group (“B4B”) including the following companies:

Payment Card Solutions (UK) Limited t/a B4B Payments (05941947) (“B4B-UK”) UAB B4B Payments Europe (305539054) (“B4B-EU”)

B4B-UK is authorised by the Financial Conduct Authority to conduct electronic money service activities under the Electronic Money Regulations 2011 (Ref: 930619). B4B-EU is authorised by the Bank of Lithuania as an Electronic Money Institution (Licence No: 76) under the Law on Electronic Money and Electronic Money Institutions 2011. B4B-US operates as a partner of Metropolitan Commercial Bank of New York. B4B provides corporate payment solutions including cards and bank transfers.. The purpose of this Anti-Money Laundering / Counter-Terrorist Financing (“AML/ CTF”) Risk Appetite Statement (the “Statement”) is to define B4B’s tolerance and the guiding principles governing Money Laundering and Terrorist Financing (“ML/TF”) risk identification, measurement, reporting, management and monitoring, as required by applicable laws in the countries in which it operates. B4B also carries the reputational risk that some of its Clients process funds that are connected with Money Laundering or Terrorism Financing activities.

B4B Payments Risk Appetite Statement

B4B maintains a zero tolerance for regulatory/compliance risk exposure. B4B ensures that it adopts all regulatory, legal requirements and compliance requirements in a proportionate way that satisfies the requirements of the local regulatory authorities in a pragmatic and cost effective manner. The on-going cost of compliance is a cost of doing business and should not be material in terms of annual income. It aims to comply with all regulatory requirements and thus avoid any penalties. B4B also maintains a zero tolerance for ML/TF risk. B4B is obliged to transact its business so as to ensure it minimises the risk of its systems and processes being used for ML or TF purposes. B4B has a risk appetite and practices which place it at the ‘best practice’ end of international standards, in relation to preventing Money Laundering and Terrorism Financing abuses. B4B has strict and transparent standards and continuously seeks to strengthen its processes to ensure compliance with all applicable laws and regulations. B4B reserves the right to reject any client, payment, or business that is not consistent with its Risk Appetite.

Accepted Business

As a general principle, B4B Payments shall not onboard Clients carrying out businesses or activities that are illegal, conducted in the absence of required licences or permissions, or which present an excessive reputational risk (which includes any material adverse media) for B4B Payments.

In the case of Correspondent Banking relationships, including Agency / Distributor / Intermediary type of relationships, the underlying customers must also comply with this requirement.

In general, B4B Payments will not do business with groups, legal entities, bodies, and similar entities which have been sanctioned for major offences or have been added to any of the sanctions list B4B is obliged to follow. However, in some circumstances, the Customer Committee may approve such Clients undertaking a Risk-Based Approach (considering the nature of offences and the time passed since it was committed depending on the facts and merits; compulsory sanctions lists are out of scope for risk-based approach).

Prohibited clients

B4B Payments does not onboard, nor will it process any payment flows, for the following:

  • Groups, legal bodies or similar subject to international sanctions or embargoes, in particular as issued by the HM Treasury (UK), the European Union (“EU”), the United Nations (“UN”) or the US Office of Foreign Assets Control (“OFAC”) including the List of Specially Designated Nationals and Blocked Persons and Lithuanian Financial Crime Intelligence Unit (“FCIS”) issued list in accordance with its sanctions policy
  • “Non-standard” or “non-transparent” activities – those carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency, or which do not meet international banking standards in the specific country involved
  • Shell banks: (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups).
  • Shell companies; (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);
  • Bearer share corporations and companies connected to a nominee or similar arrangements to hide or mask the true beneficial ownership (some trust structures may be permitted, depending on the merits of the case and there is no suggestion of untoward behaviour).
  • Physically present Adult Services – this includes, but is not limited to Escort services, sale and/or advertising or suggestion of sexual services that may imply or suggest prostitution, regardless of whether it is legal in the specific country involved.
  • Unregulated or offshore holding/investment companies involved in managing or investing own or third-party funds.
  • True holding companies with no business operations.
  • Any involvement in the sale or marketing of Binary Options
  • Weapons of war, automatic weapons, ammunition, or defence equipment: Includes merchants involved in the sales, intermediation or commerce of war or automatic weapons, including but not limited to chemical weapons, cluster bombs, ammunitions, or other defence equipment or similar.
  • Virtual Currencies / Crypto Asset firms (including firms engaged in exchange services between virtual currencies and fiat currencies).
  • Gambling / Gaming
  • Any business involved with Cannabidiol “CBD”.

Restricted Client Types

Please note that payment flows, available payment types and other similar restrictions may be applicable for the client types listed in the following paragraphs. These flows are limited by B4B correspondent banks and therefore should be treated with caution.

The risk presented by the following types of industries is considered as ‘high risk’ (according to B4B’s Client Risk Scoring Matrix). For these categories (but not limited to these categories), B4B reserves the right to ask for additional documents during the relationship to better understand the nature of the business of the client.

B4B Payments has placed certain restrictions on the client types below

  • Adult services that are not physically present, including dating sites, websites with adult content or products, and pornography businesses. If any payments are to be made to, or received from, a business providing these services the following restrictions also apply. These businesses must:
    • Have no suggestions of escort services or the sale of physically present sexual services (solicitation/prostitution);
    • Have no material negative media which could result in material reputational damage for B4B Payments; and
    • Be incorporated within UK or EEA
  • Affiliate Marketing schemes, including network marketing, referral marketing, multi-level marketing. These businesses must:
    • Not be established as a multilevel scheme for the purpose of circumventing credit card scheme rules;
    • Comply, in letter and in practice, with distant marketing or online selling legislation, including US negative option features and EU withdrawal rights, or equivalent;
    • Not engage in aggressive tax planning or transfer pricing, make use of nominees or similar structures to hide or mask true beneficial ownership of the entities involved in the scheme;
    • Not have unfair pricing or charges, or withdrawal/cancellation rights that cannot be effectively exercised without unfair costs or penalties.

In order to support the above company shall have cancellation, pricing, consumer protection policies or similar established.

  • Charities, social service organisations and other non-profit or political organisations;
    • These institutions must be registered, or local equivalent, in the country of incorporation.
    • The organisation must be located in the UK or EEA.
    • The organisation must not sponsor or support any act of violence or hate.
  • Corporate service provider and other legal and accounting services. These must:
    • Have licensing/registration in an AML/CTF regime in the UK/EEA.
  • Crowdfunding, crowdlending and similar activities businesses. These must:
    • Hold the appropriate licence in the country or territory where they are established and provide services to;
    • Have three full years or more track record; and
    • Be established within the countries permitted for correspondent relationships.
  • Drugs and pharmaceuticals (includes any drug paraphernalia, pseudo-pharmaceuticals, substances designed to mimic illegal drugs, and any other associated product, service or equipment.) These must:
    • Possess the appropriate licences in those jurisdictions where they are established or sell products into.
  • Precious metals and stones, arts and antiques, other valuable commodities, sale of vehicles or other merchants dealing with high-value goods. These must:
    • They must be established in the UK/EEA. Enhanced Due Diligence must be applied to mitigate the increased risk these industry types present;
    • supporting documentation of its purchases.
  • Weapons (i.e. knives and accessories for weapons intended for hunting, fishing and recreational activities; antique weapons or collectables). These must:
    • Be evidenced to be for legitimate sports or recreational activities and not for military or dual-use purposes.
  • Financial services firms:
    • Clients must be licensed in a permitted country (EEA and UK)
    • locations of these underlying customers are subject to review and their acceptance will be determined case by case on a risk-based approach taking into consideration their licence, and their risk profile, which will include reviewing the underlying customer base, and locations, and risk of the services provided.
    • Enhanced due diligence will be applied, including onsite/online visits when considered appropriate
  • Marketplaces: These must:
    • Have a five-year or more track record;
    • Onboard sellers under financial services-equivalent standards; and
    • Not process flows through B4B Payments that relate to goods or services that are prohibited within this statement.
  • Import/export and cross-border logistics companies including maritime and land-based shipping. These businesses:
    • Must exercise supply chain due diligence to ensure that recipients and counterparties to a transaction are not sending or receiving commodities that may trigger sectoral sanctions.
    • May not have activities involving countries considered prohibited by B4B Payments
    • May not deal with illicit or illegal goods or sanctioned entities.

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© 2006 – 2024 Payment Card Solutions (UK) Limited trading as B4B Payments is a financial technology company authorised by the Financial Conduct Authority to conduct electronic money service activities under the Electronic Money Regulations 2011 (Ref: 930619). UAB B4B Payments Europe is authorised by the Bank of Lithuania as an Electronic Money Institution (Licence No: 76) under the Law on Electronic Money and Electronic Money Institutions 2011.

In Europe, Cards are issued by B4B Payments pursuant to license by Mastercard International Inc. Mastercard is a registered trademark, and the circles design is a trademark of Mastercard International Incorporated.

All communications should be sent to: Europe – PO Box 76256, London, SW1P 9NU. USA – B4B Payments, 40 Washington Street Suite 150 Wellesley, MA. 02481.

B4B wants to ensure our customers know that their security is of the utmost importance. As such, we will never ask you to tell us your passwords, card PINs or One-Time Passcodes (OTPs).

At B4B Payments, we have taken all necessary steps to secure customer data and protect their privacy. Our systems have been designed with numerous layers of encryption and stringent firewalls. We use a combination of biometrics, two-factor authentication and other methods when customers access our services online or via our app.