Last Updated: 15 May 2026

1. Introduction

This Policy defines the standards and procedures implemented by Corytech (the "Company") to prevent money laundering, terrorist financing, and other financial crimes. As a technical payment orchestrator and Software-as-a-Service (SaaS) provider, Corytech is committed to maintaining a secure and transparent business ecosystem by performing rigorous due diligence on its corporate clients (Merchants).

2. Company Status and Regulatory Perimeter

Corytech is a technology vendor providing infrastructure for payment routing and orchestration. The Company is not a bank, payment service provider (PSP), or financial intermediary. Corytech does not hold, store, or transfer funds. Our role is strictly limited to the technical transmission of data between our Clients and their respective financial partners.

3. Merchant Due Diligence (KYB - Know Your Business)

Corytech applies a risk-based approach to the onboarding of all corporate clients. No Merchant is granted access to the technical platform without completing the following verification steps:

  • Entity Identification: Verification of corporate registration, legal status, and business address.
  • Beneficial Ownership (UBO): Identification and verification of ultimate beneficial owners holding 25% or more of the entity.
  • Business Nature Analysis: Review of the Merchant's products, services, and target markets to ensure they align with our acceptable use policies.
  • Sanctions Screening: All entities and associated individuals are screened against international sanctions lists, including OFAC, EU, and UN.

4. Ongoing Monitoring

Corytech performs continuous monitoring of its relationship with Merchants. This includes:

  • Periodic reviews of KYB documentation to ensure information remains current.
  • Technical monitoring of transaction volumes and patterns to detect anomalies that may indicate a change in the Merchant's risk profile.
  • Immediate suspension of technical services if a Merchant is found to be in violation of legal requirements or internal compliance standards.

5. Anti-Fraud & Technical Controls

While the final responsibility for transaction-level AML reporting lies with the licensed financial institutions, Corytech employs advanced technical filters to protect its infrastructure such as:

  • Technical blocking of IP addresses and entities from high-risk or sanctioned jurisdictions.
  • Velocity checks and pattern recognition to mitigate fraudulent activity at the technical layer.

6. Sanctions Compliance and Prohibited Jurisdictions

Corytech maintains a zero-tolerance policy regarding sanctioned jurisdictions and high-risk territories.

  • Strict Prohibition: Our services and technical infrastructure are strictly unavailable to entities, individuals, or any associated parties located in or originating from sanctioned countries.
  • Specific Restrictions: We emphasize a total ban on any cooperation or technical routing involving russia and belarus. Corytech does not engage with residents, legal entities, or beneficial owners associated with these territories.
  • Right to Refuse: Corytech reserves the absolute and unilateral right to refuse onboarding, suspend technical access, or terminate any existing cooperation immediately upon the slightest suspicion of a Client’s direct or indirect involvement, connection, or facilitation of transactions with sanctioned jurisdictions or their residents.
  • Technical Enforcement: Our system employs automated geo-blocking and technical filters to prevent any attempts at unauthorized use from prohibited regions.

7. Data Protection

All KYB and corporate data is processed in accordance with the GDPR and Corytech’s Privacy Policy, utilizing high-level encryption for storage and transmission.