1. Regime#
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, and the JMLSG guidance for the financial services and electronic money sectors. The Boundless wallet operates today through Stripe Payments UK Ltd as the authorised PI; the framework here mirrors theirs and adds telecoms-specific overlays.
2. Customer due diligence#
| Customer type | Standard CDD | Enhanced DD trigger |
|---|---|---|
| Personal | Name, DOB, address verified to electoral roll / credit-bureau standard or equivalent docs | PEP, sanctions hit, high-risk geography, large/unusual flow |
| Business | Companies House data, UBOs ≥25%, proof of address, ID for signatory | Complex ownership, opaque jurisdictions, high-risk sector |
3. Ongoing monitoring#
Transaction monitoring rules tuned for typical wallet/referral flows. Anomalies trigger MLRO review. Annual customer review for higher-risk relationships.
4. Reporting#
Suspicious Activity Reports filed with the NCA via the SAR Online portal where the threshold is met. Tipping-off prohibited.
5. Training#
Annual mandatory training for all staff with customer or financial responsibilities. MLRO maintains training records.
6. Review & ownership#
Owner: MLRO. Reviewed annually. Cross-references: Sanctions Policy, Whistleblowing Policy.
Version history
| Version | Date | Change |
|---|---|---|
| v1.0 | 22 April 2026 | Initial publication. |
This document is published by Boundless Telecom Ltd and forms part of our public legal posture. It is a living document - we update it as the regulatory environment, our supply chain or our products change. If anything here is unclear or you'd like a counter-signed copy, contact legal@boundless.tel and we'll respond within one working day.