1. Purpose and Scope The purpose of this policy is to establish and communicate Arena Plus Ltd.’s framework for preventing its services from being exploited for money laundering, terrorist financing, or other illicit activities.
This policy applies to all: - Business units, employees, contractors, directors, and agents of ArenaPlus Ltd. - Products, services, technologies, and channels offered by ArenaPlus Ltd. globally.
ArenaPlus Ltd. is committed to maintaining the highest standards of regulatory compliance, in line with local laws, global AML/CTF obligations, and the requirements of international card networks, including Visa and Mastercard.
2. Legal, Regulatory, and Card Scheme Framework ArenaPlus Ltd. complies with the following:
• International Standards: FATF Recommendations.
transactions involving
• Regional/Local Regulations: EU AML Directives, UK MLR 2017, and relevant local AML/CTF legislation in jurisdictions where Arena Plus Ltd. operates.
Mastercard requirements
• Card Scheme Rules: Visa and Mastercard requirements for PSPs, including:
– Merchant due diligence and onboarding obligations.
– Prohibition on facilitating transactions involving illegal or prohibited goods/services.
– Ongoing merchant monitoring and reporting requirements.
– Adherence to PCI DSS and transaction integrity standards.
3. Risk-Based Approach (RBA) Arena Plus Ltd. employs a structured risk-based approach, consistent with Visa, Mastercard, and FATF guidance. Risk assessments are periodically conducted to evaluate:
• Customer Risk – merchant type, ownership structure, jurisdiction, business model.
• Product/Service Risk – cross-border payments, high-value transactions, recurring billing, anonymity.
• Channel Risk – e-commerce, mobile, third-party integrations, agent/ISO arrangements.
• Geographic Risk – customers or transactions linked to high-risk or sanctioned jurisdictions. Enhanced controls are applied where higher risks are identified.
4. Customer Due Diligence (CDD) and Merchant Onboarding Prior to establishing any merchant relationship, Arena Plus Ltd. undertakes CDD, consistent with regulatory and card scheme requirements:
• Identification and Verification: Full KYC/KYB checks, including beneficial ownership (25%+), corporate structure, and business activity validation.
• Enhanced Due Diligence (EDD): For high-risk sectors, politically exposed persons (PEPs), and merchants operating in FATF high-risk or non-cooperative jurisdictions.
• Merchant Acceptance Policy: Strict adherence to Visa/Mastercard rules on prohibited merchants, restricted industries, and high-risk MCCs (Merchant Category Codes).
• Ongoing Monitoring: Continuous review of merchant profiles, transaction volumes, and business activity.
5. Transaction Monitoring and Fraud Prevention Arena Plus Ltd. deploys automated monitoring systems, supported by manual oversight, to identify suspicious or prohibited activities. Key controls include:
• Detection of unusual transaction patterns(structuring, velocity, volume anomalies).
• Monitoring chargeback levels and fraud ratios against card scheme thresholds.
• Sanctions and PEP screening at onboarding and continuously thereafter.
• Real-time alerts for transactions involving restricted or prohibited MCCs.
• Monitoring for use of anonymizing technologies, synthetic identities, or shell companies.
6. Record Keeping Arena Plus Ltd. retains records in accordance with regulatory and card scheme requirements:
• Minimum of five (5) years from the end of the business relationship or date of transaction.
• Records include CDD/KYB documentation, merchant agreements, transaction histories, and Suspicious Activity Reports (SARs).
• Records are stored securely, ensuring accessibility for regulatory authorities, auditors, and card schemes upon request.
7. Reporting Obligations All employees must escalate suspicious activity to the Money Laundering Reporting Officer (MLRO).
• The MLRO will determine whether to file a SAR with the appropriate Financial Intelligence Unit (FIU).
• Reports are handled confidentially, and “tipping off” is strictly prohibited.
• The MLRO will liaise with card schemes(Visa/Mastercard) if merchant activity suggests non-compliance with card scheme rules or fraud thresholds.
8. Sanctions and Prohibited Activities Arena Plus Ltd. does not tolerate business relationships or transactions involving:
• Individuals or entities subject to UN, EU, UKHMT, OFAC, or other applicable sanctions.
• Merchants offering illegal or card-scheme-prohibited products/services.
• Transactions linked to terrorism, human trafficking, narcotics, or other criminal enterprises. All customers and merchants are screened against relevant sanctions lists both at onboarding and continuously thereafter.
9. Training and Awareness All employees, especially those in compliance, risk, operations, and merchant support, undergo mandatory AML/CTF training. Training covers:
• AML/CTF obligations and internal procedures.
• Visa/Mastercard merchant acceptance and monitoring rules.
• Recognition and reporting of suspicious activity.
• Consequences of non-compliance (regulatory penalties, card scheme fines, reputational damage).
10. Governance and Accountability
• Board of Directors: ultimate accountability for AML/CTF compliance and oversight of governance framework.
• Money Laundering Reporting Officer (MLRO): responsible for the effective implementation of the AML/CTF program, regulatory liaison, and reporting.
• Compliance Department: ensures day-to-day adherence to AML/CTF procedures and card scheme rules.
• Employees: responsible for applying AML/CTF policies and escalating concerns.
11. Policy Review This policy is reviewed annually, or sooner if required by:
• Changes in regulatory obligations.
• Visa/Mastercard rule updates.
• Internal risk assessments or audit findings.
All amendments are approved by the Board of Directors and communicated to relevant stakeholders.