Last updated December 10, 2021
Thank you for choosing to be part of our community at Movo, Inc (“Movo”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
Movo Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Movo being involved in any kind of illegal activity.
Both international and local regulations require Movo to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, corruption and bribery and to take action in case of any form of suspicious activity from its customers.
In Short: We adopt a risk-based approach and priorities greatest risk and give it the highest attention.
Movo, in line with domestic laws and requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Movo is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
We are Movo, a financial services platform; offering consumer a better and easier way to spend, save and mange their money. We are on a mission to help drive financial inclusion and financial wellness by building a product that people love and trust.
Our software and services are developed with privacy and data protection in its core, the sole purpose of our services is to drive financial wellness and facilitate payments between consumer and businesses and vice versa.
Movo, Inc (A.K.A. Movo) registered in Egypt and Delaware - US.
Registered Office: El Obour Buildings, Salah Salem, Cairo - EGYPT.
Head Office: South 90, New Cairo, Cairo - EGYPT.
You can drop us an email at anytime email@example.com.
There are many different ways to contact us. The main ones are listed below. Please also see the ‘Movo websites and social media’ section for other ways to contact us and our information collection and use practices when you do so. You can also contact us from the Movo app and there is more information on that in the ‘Movo app’ section.
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
In Short: Our compliance process requirers collection of identification data, building policies and compiling reports to adhere by regulations and laws.
The Compliance Officer is the person, duly authorised by Movo, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Movo's, partner banks and the regulatory body anti-money laundering and counter-terrorist financing, including but not limited to:
Collecting Users’ identification information;
Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
Monitoring transactions and investigating any significant deviations from normal activity;
Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
Updating risk assessment regularly;
Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
In Short: We verify all customers identity and documents and run regular checks against domestic and international sanctions list to keep up with regulations.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Movo establishes its own verification process within the standards of anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).
Movo’s identity verification procedure requires the customer to provide Movo with reliable, independent source documents, data or information (e.g., national ID, international passport, utility bill). For such purposes Movo reserves the right to collect User’s identification information for the AML/KYC Policy purposes.
Movo will take steps to confirm the authenticity of documents and information provided by the customers. All legal methods for double-checking identification information will be used and Movo reserves the right to investigate certain customers who have been determined to be risky or suspicious.
Movo reserves the right to verify customers identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular customer). In addition, Movo reserves the right to request up-to-date documents from the customers, even though they have passed identity verification in the past.
Once the customer’s identity has been verified, Movo is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
Movo is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Movo will therefore screen against Domestic and International sanctions lists in all jurisdictions in which we operate.
In Short: Monitoring transactions is necessary to fulfil the purposes outlined in this AML/KYC policy and as required by law.
The Users are known not only by verifying their identity (who they are) but, more importantly, by analysing their transactional patterns (what they do). Therefore, Movo relies on data analysis as a risk-assessment and suspicion detection tool. Movo performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
Regular check of customers against recognised “black and sanctions lists”, aggregating transfers by multiple data points, placing customers on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
Case and document management.
In Short: Movo will monitor all transactions for suspicious behaviour or patterns and report any if need to compliance officers and regulatory bodies.
With regard to the AML/KYC Policy, Movo will monitor all transactions and it reserves the right to:
Ensure that transactions of suspicious nature are reported to the proper law enforcement through the compliance;
Request the customer to provide any additional information and documents in case of suspicious transactions;
suspend or terminate customer’s account when Movo has reasonably suspicion that such customer engaged in illegal activity.
The above list is not exhaustive and the compliance will monitor customers’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.