Legal
Our commitment to preventing money laundering, terrorist financing and financial crime — and what that means for you as a customer.
ClickSend Money is committed to preventing its services from being used for money laundering, terrorist financing, sanctions evasion, fraud or any other financial crime. We maintain a risk-based financial crime programme designed to meet the legal and regulatory requirements of every jurisdiction we operate in, overseen by a nominated Money Laundering Reporting Officer (MLRO) with board-level accountability.
Our framework is built on written policies and procedures covering customer due diligence, sanctions and PEP screening, transaction monitoring, suspicious activity reporting, record keeping and training. It follows the UK Money Laundering Regulations, the Proceeds of Crime Act and Terrorism Act, EU anti-money-laundering directives where we operate in the EEA, and guidance from FATF and the Joint Money Laundering Steering Group. The programme is risk-based: controls are strongest where the risk — by customer, corridor, product or delivery channel — is highest, and it is independently reviewed on a regular cycle.
We verify the identity of every customer before they can send money. Know Your Customer (KYC) checks include verifying your name, date of birth and address against government-issued identity documents and independent data sources, and may include biometric liveness checks in the app.
Enhanced due diligence applies where risk is higher — for example larger or unusual transactions, higher-risk corridors, or customers identified as politically exposed. It can include requesting evidence of source of funds or source of wealth, additional documentation, and senior-management approval before a transaction proceeds.
Every customer and every transaction — sender and recipient — is screened against applicable sanctions and asset-freeze lists, including those issued by the Office of Financial Sanctions Implementation (HM Treasury), the UN, the EU and OFAC, as well as lists of politically exposed persons (PEPs). Potential matches are investigated before funds are released, which can delay a payout; confirmed matches are blocked and reported as the law requires.
We monitor transactions before and after execution using automated rules and behavioural analysis, looking for patterns such as structuring, rapid movement of funds, activity inconsistent with a customer's profile, and links to high-risk jurisdictions. Alerts are reviewed by trained analysts, who may pause a transfer and request more information before it is released.
Where we know or suspect that funds are linked to criminal activity, we file a suspicious activity report with the relevant financial intelligence unit — in the UK, the National Crime Agency. The law prohibits us from telling a customer that a report has been made ("tipping off"), so we may be unable to explain why a transaction has been delayed or declined.
We combine device intelligence, payment-instrument verification and behavioural checks to detect account takeover, scams and unauthorised payments. Our service must only be used to send money to people you know and trust. If you believe you have been targeted by a scam or that your account has been compromised, contact us immediately on 0800 048 2233.
We may delay, decline or reverse any transaction, or suspend or close an account, where we cannot complete our checks, where a transaction presents a risk we are not willing to accept, or where the law, a regulator, a law-enforcement body or a court requires it. We do not serve customers, or process transactions to or from persons or jurisdictions, where doing so would breach applicable sanctions.
We keep records of customer identification, due diligence and transactions for at least five years after the transaction or the end of the customer relationship, and longer where the law requires. Records are held securely and handled in line with our Privacy Policy.
All staff receive financial-crime training on joining and at least annually thereafter, with role-specific training for compliance, operations and customer-facing teams. Training covers recognising suspicious activity, sanctions obligations, internal reporting and the consequences of failure to comply.
We cooperate fully with our regulators, financial intelligence units and law enforcement, including responding to information requests and production orders. Details of our regulatory registrations in each region are on our Licences page.
This statement is reviewed at least annually and updated when our controls or legal obligations change. Questions can be directed to help@clicksend-money.com.