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NUMODEV, računalniško programiranje, d.o.o. is committed to preventing its technology being used to launder money, finance terrorism, evade sanctions or commit fraud. This statement summarises our approach and what we require of the partners who operate tenants on the Platform.
It is a summary of our internal programme, not a substitute for it, and it does not constitute legal or compliance advice to partners.
1. Our role, and yours
omwio supplies software. We do not hold, receive or settle client funds, and we are not the payment service provider of record for any merchant. Regulatory obligations attaching to the payment activity itself — customer due diligence on merchants, transaction monitoring, suspicious activity reporting to the relevant financial intelligence unit — rest with the partner operating the tenant and with its licensed providers.
That does not make us indifferent. We conduct due diligence on the partners we onboard, we build the controls partners need to meet their own obligations, and we act where we see the Platform being misused.
2. Risk-based approach
We assess each prospective partner before provisioning a tenant, and periodically thereafter. Assessment considers the partner’s ownership and control structure, jurisdiction, licensing status, the merchant categories it intends to serve, expected volumes and the payment methods requested. The depth of due diligence and the frequency of review scale with the assessed risk.
3. Partner due diligence
- Verification of the legal entity, its registration and its registered address.
- Identification and verification of beneficial owners and directors.
- Confirmation of any licences or registrations the partner relies on.
- Screening of the entity, its owners and its directors against sanctions, PEP and adverse media sources, repeated on an ongoing basis.
- Understanding of the intended merchant base and the source of expected volume.
4. Sanctions
We do not onboard partners subject to applicable sanctions regimes, owned or controlled by sanctioned persons, or established in comprehensively sanctioned territories. Screening is repeated as lists change, and a positive match results in immediate escalation and, where required, suspension.
5. Prohibited and restricted activity
Partners must not use the Platform to process for activity that is unlawful in a relevant jurisdiction. The following are prohibited outright, and further categories may be restricted or made conditional in your order form.
- Child sexual abuse material, human trafficking or forced labour.
- Trade in weapons, explosives or controlled substances outside a licensed framework.
- Terrorist financing or transactions involving sanctioned parties.
- Fraudulent schemes, including pyramid and Ponzi structures and deceptive subscription traps.
- Unlicensed financial services, gambling or money transmission where a licence is required.
- Sale of stolen goods, counterfeit items or unlawfully obtained data.
6. Controls available to partners
The Platform provides controls partners can use to meet their own monitoring obligations: rule and velocity screening on the transaction create path, provider and route monitoring, structured dispute and chargeback workflows, balance history with reserve visibility, settlement reconciliation with explicit breaks, and permission-gated review steps on sensitive operations such as batch payout release.
Availability of some controls depends on the modules enabled in the partner’s billing plan. Partners are responsible for configuring them appropriately for their risk profile.
7. Monitoring, escalation and reporting
We monitor platform-level signals for indications of misuse. Where we identify activity that suggests the Platform is being used for financial crime, we escalate internally, may suspend access, and cooperate with law enforcement and regulators where legally required.
We do not file suspicious activity reports on behalf of partners; that obligation, where it applies, is theirs. We will not tip off a subject where doing so is prohibited.
8. Record keeping
Due diligence records, screening results and escalation decisions are retained for the period required by applicable legislation, and made available to competent authorities on lawful request.
9. Governance and training
Responsibility for the programme sits with our designated compliance officer, who reports to senior management. Staff in relevant roles receive financial crime training on joining and periodically thereafter. The programme is reviewed at least annually and after any material change in our services or in applicable law.
10. Reporting a concern
To report suspected misuse of the Platform, or to raise a compliance question, write to compliance@omwio.com. Reports are treated confidentially.