Risk controls

Risk Appetite Policy

This public draft summarizes MultiPay’s risk boundaries for business-account onboarding, payment activity, third-party provider requirements, and ongoing service monitoring.

01

Purpose of this policy summary

This public Risk Appetite Policy summary describes the types of business, transaction activity, and service use that MultiPay may accept, restrict, refuse, suspend, or terminate. It is intended for general information and does not replace onboarding questionnaires, client agreements, compliance policies, partner requirements, or internal risk-control procedures.

MultiPay’s risk appetite may change based on applicable law, regulatory expectations, sanctions developments, fraud trends, partner-bank requirements, payment-network rules, operational capacity, and internal risk assessments.

02

Business-client suitability

MultiPay services are intended for approved business and corporate clients with legitimate commercial payment needs, transparent ownership, identifiable authorized signatories, lawful source of funds, and a business model that MultiPay can understand and monitor.

Applicants may be refused or required to provide additional information if the business activity, ownership structure, jurisdictional exposure, transaction purpose, expected counterparties, volume profile, or documentation does not satisfy MultiPay’s risk appetite, third-party provider requirements, or compliance obligations.

03

Restricted and prohibited activity

MultiPay does not intend to support unlawful, deceptive, sanctioned, fraudulent, abusive, or unlicensed activity. MultiPay may reject business involving sanctions evasion, terrorist financing, money laundering, fraud, human trafficking, illegal goods or services, unauthorized financial services, misrepresented beneficial ownership, false documents, undisclosed third-party activity, or attempts to bypass transaction monitoring.

Some sectors, jurisdictions, transaction types, currencies, counterparties, or payment routes may be unavailable or subject to enhanced due diligence, limits, delay, manual review, or refusal because of law, risk assessment, partner-bank requirements, payment-network rules, or operational capacity.

04

Ongoing monitoring and controls

MultiPay may review account activity, payment instructions, counterparties, transaction purpose, source of funds, supporting documentation, sanctions-screening results, fraud indicators, and third-party provider alerts. MultiPay may request additional information before or after a transaction is initiated.

MultiPay may delay, decline, freeze, reverse where possible, report, restrict, suspend, or terminate activity where required or permitted by law, partner requirements, security concerns, risk controls, incomplete information, suspicious activity, or breach of applicable terms.

05

Third-party provider requirements

MultiPay services may depend on authorized banking partners, payment networks, processors, foreign-exchange providers, compliance-data providers, technology providers, intermediary institutions, and other operational service providers. Those providers may apply their own due-diligence standards, operational procedures, limits, cut-off times, eligibility rules, and refusal rights.

A transaction or service feature may therefore be unavailable, delayed, suspended, or declined even where MultiPay has accepted an inquiry or previously processed similar activity. MultiPay does not guarantee that a third-party provider will approve, process, settle, reverse, retrieve, or support any specific transaction.

06

No circumvention or misuse

Clients must not use MultiPay services to process payments for undisclosed third parties, conceal ownership or transaction purpose, split transactions to avoid review, evade sanctions or reporting controls, exploit operational delays, interfere with portal security, or provide misleading documentation.

MultiPay may update this public summary at any time. Final risk appetite, acceptance, limits, and controls are determined by MultiPay, applicable law, third-party provider requirements, and any binding client agreement.

Questions about this document?

Contact MultiPay for business-account inquiries. Formal notices may require a different delivery method under an applicable agreement.

Contact MultiPay