AML & Compliance Policy
1. Statement of Commitment
E&GPay, Inc. (“E&GPay”) is committed to operating in full compliance with applicable anti-money laundering (AML) laws, anti-corruption regulations, and global best practices. Although E&GPay does not itself provide financial services, we take our responsibility seriously in preventing misuse of our administrative and marketing services for illicit purposes.
2. Legal Status of E&GPay
E&GPay is a Wyoming-based marketing and consultancy firm. We do not:
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Issue financial instruments;
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Hold or transfer customer funds;
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Provide banking or payment processing services;
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Engage in regulated financial activities.
All financial services introduced by E&GPay are provided exclusively by third-party institutions licensed and regulated in Brazil. E&GPay operates only as a commercial liaison and onboarding facilitator.
3. Anti-Money Laundering (AML) Policy
We implement internal protocols to prevent the use of our services in connection with:
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Money laundering;
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Terrorist financing;
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Fraud or identity theft;
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Sanctions evasion;
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Tax evasion or avoidance;
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Corruption and bribery.
E&GPay reserves the right to refuse or terminate services where reasonable suspicion of illegal conduct exists.
4. Know Your Client (KYC)
Though KYC is conducted by the Brazilian financial institution, E&GPay collects and preliminarily reviews client documentation to assist in onboarding. This may include:
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Proof of company registration (CNPJ in Brazil);
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Identification documents for beneficial owners;
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Proof of business address;
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Information on source of funds and business activities.
We may request further details at any time and are under no obligation to proceed with onboarding if compliance concerns arise.
5. Politically Exposed Persons (PEP)
A Politically Exposed Person (PEP) is defined as an individual who is or has been entrusted with a prominent public function, including their immediate family members and close associates.
E&GPay applies enhanced due diligence procedures for Clients identified as PEPs, including:
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Disclosure requirements;
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Enhanced background checks;
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Documentation regarding source of wealth and funds.
We reserve the right to decline onboarding of high-risk PEPs at our sole discretion.
6. Sanctions and Prohibited Jurisdictions
E&GPay complies with international sanctions regimes including those imposed by:
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The U.S. Department of the Treasury (OFAC);
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The United Nations;
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The European Union.
We do not accept Clients who are residents of or associated with countries or territories subject to comprehensive economic sanctions, nor do we serve individuals or entities listed on any official sanctions lists.
7. US Persons & Regulatory Restrictions
E&GPay’s services are not available to U.S. Persons as defined under U.S. tax and financial regulation. We do not offer or promote financial services within the United States or to any party that may trigger regulatory obligations under:
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The Bank Secrecy Act (BSA);
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The USA PATRIOT Act;
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FinCEN regulations;
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IRS FATCA requirements.
8. Anti-Corruption Policy
E&GPay maintains a zero-tolerance policy toward bribery, facilitation payments, and other forms of corruption. All employees, contractors, and affiliates are prohibited from:
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Offering or accepting bribes;
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Engaging in conflicts of interest;
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Facilitating payments to public officials.
Suspicious behavior must be reported to management and may result in termination and legal reporting.
9. Tax Compliance
E&GPay does not promote or participate in tax evasion or undeclared asset strategies. Clients are solely responsible for compliance with applicable tax reporting obligations in their respective jurisdictions.
We reserve the right to cooperate with authorities in cases of suspected tax fraud or undeclared income.
10. Recordkeeping
All client documentation collected during the onboarding process is stored securely for a minimum of five (5) years. Access is restricted and used solely for compliance verification and lawful purposes.
11. Reporting of Suspicious Activity
E&GPay reserves the right to:
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Refuse service without notice;
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Suspend onboarding processes;
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Report suspicious activity to the relevant Brazilian Service Provider or applicable legal authority (as required or advisable).
12. Amendments
This policy may be updated periodically to reflect changes in regulation, risk assessment, or operational practices. The latest version is always available at www.egpay.global/compliance.
13. Contact Us
If you have questions or wish to report a concern related to our compliance program:
Email: customer@egpay.us
Disclaimer
This document is for informational purposes only and does not constitute legal or financial advice. E&GPay does not act as a financial institution, fiduciary, or regulated entity.