Anti-Money Laundering Management Requirements for Overseas Acquirers

The management requirements apply to Alipay overseas cooperative acquirers.


I    Definitions

1.     “Overseas” means all countries and regions outside mainland China, including Hong Kong, Macau and Taiwan.

2.     “Overseas Acquirer(s)” means acquirers or banks which provide overseas payment services.

3.     “Secondary Merchants” means the overseas merchant who does not enter into agreements with Alipay directly but getting access to Alipay overseas acquiring service and making its transaction amount settlement through Overseas Acquirers.

4.     “UBO”, Ultimate Beneficial Owner, means the natural person who controls the company or holds more than 25% equity interests or voting rights, directly or indirectly, in the company or controls the company by way of personnel or finance controlling.

5.     “Merchant Certificate Document(s)” means Certificate of Incorporation, Articles of Incorporation or other documents in the similar nature which can certify their duly incorporation.

6.     “Merchants’ Identification Recognition” means registering basic information and retaining current identification certificates of merchants.

7.     “Due Diligence” means investigating the business scope, major upstream suppliers and downstream target clients and the actual controller of merchants.

8.     “Sanction List” means the terrorist organizations and terrorists list announced or requested to be executed by PRC government; the list set out in the resolution of United Nation Security Council.

9.     “Suspicious Transaction Report” means the transaction reports where Alipay discovers or suspects on a reasonable basis that a client, the funds or any other assets of a client, or the transaction conducted or to be conducted by a client connected with money laundering, financing of terrorism or any other criminal activities.


II    The Anti-Money Laundering Management Requirements for Overseas Acquirers

1.     The Overseas Acquirers shall set up a complete management mechanism for anti-money laundering, including rules for merchants’ identification recognition (including Due Diligence), lists screening and suspicious transaction monitoring mechanism, provided that anti-money laundering obligations required to be performed by the Overseas Acquirers in accordance with applicable laws and regulations.

2.     The Overseas Acquirers shall set up a management mechanism for merchants’ identification recognition (including Due Diligence) provided that no anti-money laundering obligations required to be performed by the Overseas Acquirers in accordance with applicable laws and regulations.


III    Overseas Acquirers’ Obligations on Secondary Merchants Anti-Money Laundering Management

1.    KYC Management for Secondary Merchants

  a)   Record the complete information of Secondary Merchants, including but not limited to the name, business scope, operating place (website), the name, identification number, type of certificate, nationality, date of birth of its legal representative and the name, type of certificate, identification number, nationality, date of birth of the UBO of Secondary Merchants.

  b)   Record the complete merchant certificate documents of Secondary Merchants.

  c)   Keep continuous investigations on operation conditions of Secondary Merchants, getting to know whether the Secondary Merchant is continuous operating (whether the website is valid or the business of the retail store is on the regular track), whether the business scope of Secondary Merchants has been changed and making a full record regarding the onsite visit.

2.    List Screening (Only applicable to Overseas Acquirers who are subject to anti-money laundering obligations in accordance with local regulations)

  a)   Keep screening mechanism for Sanction List during the onboarding of Secondary Merchants, scanning the documents of Secondary Merchants and their legal representatives and UBO.

  b)   Maintain continuous screening mechanism for Sanction List during the process of cooperating with Secondary Merchants.

  c)   Retain the complete records for the screening and processing procedures.

3.    Suspicious Transaction Monitoring (Only applicable to Overseas Acquirers who are subject to anti-money laundering obligations in accordance with local regulations)

  a)   Keep continuous monitoring of the operational conducts of Secondary Merchants. Recognize, analyze and submit suspicious transaction report to the local regulatory authorities.

  b)   Retain the complete records for the analyzing and reporting procedures.


Updated on August 27, 2018

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