Home AML/KYC Policy

AML/KYC Policy

Last updated: 25th August 2025


SUPERB PAYMENTS UAB Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of SUPERB PAYMENTS UAB being involved in any kind of illegal activity.

International and local regulations require SUPERB PAYMENTS UAB to implement effective internal control system and procedures and measures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Customers.

For Law Enforcement requests please direct your official document to our compliance team here.

AML/KYC Policy covers the following matters:

- Verification/Onboarding procedures.

- MLRO Officer.

- Monitoring transactions.

- Risk assessment


1. Verification/Onboarding procedures

One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to AML/KYC policy, SUPERB PAYMENTS UAB establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs).

SUPERB PAYMENTS UAB identity verification procedure requires the Customer to provide SUPERB PAYMENTS UAB with reliable, independent source documents, data or information (e.g., national ID, International passport, bank statement, utility bill). For such purposes SUPERB PAYMENTS UAB reserves the right to collect Customer’s identification information for the AML/KYC Policy purposes.

SUPERB PAYMENTS UAB will take steps to confirm the authenticity of documents and information provided by the Customers. All legal methods for double-checking identification information will be used and SUPERB PAYMENTS UAB reserves the right to investigate certain Customers who have been determined to be risky or suspicious.


Required Documentation

Some of the following documents might be required during the verification process at superbbit.com


Identity Verification:

- Government issued International Passport

- Government issued Identity Card


Address Verification:

- Utility bill or Bank Statement, not older than 3 month

- Paper versions or electronic versions are allowed

- No modifications are allowed to the documents


Selfie:

- Advanced liveness check

Please note that all required documents should be provided in good quality, all texts should be readable, there should not be any modifications or edits of the document photos, otherwise we would have to reject them and request new copies without modification or in better quality.

You will need to comply with our identity verification procedures before you are permitted to open an Account and access and use the SUPERB PAYMENT UAB Services, whether independently or through a third-party service by https://sumsub.com/, by providing us with certain information about yourself and, where relevant, all of your Permitted Customers. All information that you provide must be complete, accurate and truthful. You must update this information whenever it changes.

You can review our Privacy Policy to have more information about how we process your personal data.


Third-Party Service Providers

You also consent to your personal information being compared to records maintained by third parties, including telecom and other service providers, and you consent to having those third parties provide personal information to us and our third-party suppliers for the purpose of identity verification.

By using the Site and submitting your identification information on the Site, you confirm your consent to us collecting, using, disclosing, and storing your personal information for the purpose of your identity verification.


Enhanced due diligence

We may also require you to comply with our enhanced due diligence procedures by submitting additional information about yourself, your business and authorized persons, providing additional records or documentation, or having face to face verification with representatives of SUPERB PAYMENT UAB.


Records

We keep your personal data to enable your continued use of SUPERB PAYMENT UAB Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, and as may be required by law such as for tax and accounting purposes, compliance with AML/CFT laws, or as otherwise communicated to you.

Please review our Privacy Policy for more information on how we collect and use your personal data relating to the use and performance of our Sites and the SUPERB PAYMENT UAB Services.


2. MLRO Officer

The MLRO Officer is the person, duly authorized by SUPERB PAYMENT UAB Services, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the MLRO Officer's responsibility to supervise all aspects of SUPERB PAYMENT UAB Services anti-money laundering and counter-terrorist financing, including but not limited to:

  1. Collecting Users' identification information;
  2. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
  3. Monitoring transactions and investigating any significant deviations from normal activity;
  4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
  5. Updating risk assessment regularly;
  6. Providing law enforcement with information as required under the applicable laws and regulations.

The MLRO Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.


3. Monitoring transactions

The Customers are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, SUPERB PAYMENT UAB Services relies on data analysis as a risk-assessment and suspicion detection tool. SUPERB PAYMENT UAB Services performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:

  1. Check of Customers against recognized "blacklists" (e.g. National and The European Union's consolidated sanctions list, OFAC, OFSI, ANO), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
  2. Case and document management.

With regard to the AML/KYC Policy, SUPERB PAYMENT UAB Services will monitor all transactions and it reserves the right to:

  1. Ensure that transactions of suspicious nature are reported to the proper law enforcement through the MLRO Officer;
  2. Request the Customer to provide any additional information and documents in case of suspicious transactions;
  3. Suspend or terminate Customer's Account when SUPERB PAYMENT UAB Services has reasonably suspicion that such User engaged in illegal activity.

The above list is not exhaustive, and the MLRO Officer may monitor Customers' transaction behavior on the on-going basis in order to reach the conclusion whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.


4. Risk assessment

SUPERB PAYMENT UAB, in line with the international standards, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, SUPERB PAYMENT UAB is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.