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muriel_volestrangler

(104,121 posts)
7. I was thinking of their personal credit cards, and that does seem likely
Thu Jun 5, 2025, 05:19 PM
Jun 5

Here's a UK Mastercard agreement from 2016 - item 8:

A License application must be accompanied by affirmative evidence satisfactory to the
Corporation that the applicant is in compliance with the MasterCard Anti-Money Laundering
Program (the “AML Program”).
The AML Program requires that each Customer conducting or proposing to conduct issuing
and/or acquiring Activity have policies, procedures, and controls in place to protect against the
use of MasterCard systems for money laundering and terrorist financing. Such policies,
procedures, and controls must apply to all Activity and include, at minimum, all of the
following:
1. Thorough client identification
2. Thorough client due diligence
3. Record-keeping of such identification and due diligence
4. Appropriate limitations on anonymous activities
5. Client activity monitoring to detect suspicious activity
6. Steps to be taken when suspicious activity is detected
7. An audit process to test controls
8. Compliance with U.S. sanctions programs, which require that:
a. Each Cardholder, Merchant and agent is checked against the Specially Designated
Nationals and Blocked Persons List (the “SDN List”) issued by the U.S. Treasury
Department’s Office of Foreign Assets Control (“OFAC”), at the time the relationship is
established and on an ongoing basis. Any Activity with a person or entity found to be
on the SDN List is immediately terminated; and
b. No Activity is conducted in a country subject to OFAC sanctions programs that impact
payment services, or with the government of such a country.
The Corporation has exclusive authority to determine at any time whether an applicant or a
Customer is in compliance with the AML Program. Each applicant to be a Customer and each
Customer must cooperate with the periodic reviews and any other efforts undertaken by the
Corporation to evaluate such applicant’s or Customer’s compliance with the AML Program. As
part of a periodic review, the Corporation may subject a Customer to enhanced due diligence
procedures which may include on-site examinations and/or the use of a third party reviewer.
Any such examination is at the expense of the Customer, and a copy of the examination
results must be provided promptly to the Corporation upon request.

https://www.mastercard.co.uk/content/dam/mccom/apac-global/documents/mastercard-rules-june-2016.pdf

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