Webtel.mobi

Security and Anti Money Laundering

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In order to make information easily and rapidly accessible, and so that Members do not have to scroll to reach information that may be interesting/relevant to them, the information on this page is listed below by category. To see information in a specific category, just click on the link, and you will be taken directly to it. Once you've read it, you can just click on the "Back to top" button at the end of each section to return to the top of the page.

 

  1. Overview

     
  2. Security Processes
  3. Anti Money Laundering
  4. Summary

 

  1. Overview

In any Company that conducts Global Business, the Security Function is critical. In the case of a Prepaid Telephony Company – where stored credit, funds and airtime are part of the business process flow – the Security Function is particularly critical.

 

The Security Function within the Company relates to three areas of consideration, they being:

 

  1. Member Security

To ensure and protect the security of Member stored credit, accounts, transactions and privacy.

 

  1. International Corporate Security

To implement monitoring and security processes to prevent illegal use of stored credit and/or illegal transactions or activities by external parties.

 

  1. Company Security
  • To implement the monitoring and security of transactions to mitigate the occurrence of fraudulent transactions to the detriment of the Company.
     
  • To ensure that the highest possible standards are adhered to in respect of all three areas of the Security Function, the Company applies the highest standards of Best Practice security requirements for all three areas.
     
  • The Company moreover exceeds these required Best Practice security requirements by applying levels of security and security processes that are not even applicable to Telephony Companies and services such as those provided by Webtel.mobi – but which are usually applicable to Financial Services companies and activities.
     
  • To achieve this, the Company employs and applies both internal and external security measures, a summary of which is as follows below:

 

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  1. Summary of the Security Facilities and Processes
  1. The entire site is HTTPS

 

HTTPS creates a secure and encrypted communications channel between the web browser and the site. This ensures protection of information, activities and transactions from eavesdroppers, “man-in-the-middle” attacks and tampering. It ensures authentication of the accessed website, and protects the privacy and integrity of the data exchanged in communications and/or transactions. More information on HTTPS can be obtained by clicking here.

 

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  1. Advanced “InAuth” Mobile Security on the site

 

The “InAuth” Security Platform is one of the most sophisticated and effective online security systems in the world. It functions on and for browsers, devices and mobile phones internationally. When the site is accessed from any internet-enabled device (PED / Desktop / Tablet / Mobile Phone / etc), the “InAuth” system immediately uniquely identifies the accessing device, and examines up to 2 000 accessing device attributes. It then combs the device to detect and assess risk indicators. The “InAuth” system is utilized by some of the world’s largest brands in the Enterprise, M-Commerce, E-Commerce, Payments and Banking Sectors. More information on the “InAuth” Security Platform can be obtained by clicking here.

 

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  1. Advanced “Accertify” Fraud Prevention on the site

 

“Accertify” is an international Industry Leader in the eCommerce Sector in the fields of Fraud Prevention, Risk Management and other related online security services. It has partnership programs with Global Credit and Debit Card Providers, Telecommunications Companies, Payment Companies, Credit Bureaus and other industry-leading companies. “Accertify” is a PCI DSS Level 1 validated Service Provider and ISO/IEC 27001:2013 compliant. More information on “Accertify” and its industry-leading services can be obtained by clicking here.

 

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  1. Hosting Security and Multiple Redundancy Layers

 

 

The site is hosted in Sweden due to that country’s proven track record in respect of the robust protection of user privacy, data protection, and the upholding of laws regarding free speech and net neutrality, and the high and consistent quality of internet services. The site is hosted by “The Online Group” which is a Swedish consortium of various specialist internet-related companies, which has a track-record of stability, reliability and tight security. There are multiple protective layers around the site which provide protections against Denial of Service Attacks and various other forms of cyber-attack. There are also multiple redundancy processes running which ensure that all Member information is protected and backed-up in real time, in geographically separated data centers, and with mirrored servers to ensure continued functioning of the site in the event of server failure in one of the data centers. This is to ensure that no Member data, transaction data, stored credit data or any other data or records are ever lost. More information on “The Online Group can be obtained by clicking here.

 

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  1. No JavaScript – prevents “Clickjacking”

 

The site was built without JavaScript for two reasons. The first reason was to enable its functionality on non-Smart Phones / pre-Smart Phones (which comprise up to 60% of all mobile phones in use). The second reason was to add an additional layer of protection, because non-JavaScript sites cannot be targeted with “User Interface Redress Attack” (“ClickJacking”), which is a growing problem internationally. More information on “User Interface Redress Attack” (“ClickJacking”) and its associated attacks can be obtained by clicking here.

 

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  1. Cross-system comparison algorithms (CSCA)

The site constantly runs in-house “cross-system comparison algorithms” to monitor unusual activity or patterns across multiple attributes / habits / patterns / activities. In the event of unusual patterns being detected, action is taken to contact the Member to confirm his or her initiating or implementation of these activities before they are allowed to proceed. An example of some (not all) of the CSCA algorithm indicators are the following:

 

  • Account Loading Rhythms.
     
  • Call Rhythms.
     
  • Text Rhythms.
     
  • Currency Conversion Rhythms.
     
  • Top-up Transfer Rhythms.
     
  • Refund Transfer Rhythms.
     
  • Login Rhythms.
     
  • Login Locations and Devices.
     
  • IP Check.
     
  • MAC check.
     
  • Device Check (Mobile / Desktop / Other).
     
  • Phone Number Check.
     
  • Email Check.
     
  • Name Check.
     
  • Internal and External Database Check.

 

Other than the above CSCA, an “Inter-system real-time cross-check” (IRC) system also runs permanently

 

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  1. Mobile Number Authentication (MNA)

In order to join the site, a Member must provide a unique mobile number to be used as a Primary Mobile Number. If the number is not unique it will not be accepted. If the number has already been entered into the site it will not be accepted. If accepted, a unique Transaction Authentication Number (TAN) is sent to the Member’s Mobile Phone by text message. If the unique TAN is not entered, the Member cannot join. If the process runs smoothly and the Member is able to join, this means that his unique mobile number is recorded. As people need to provide their KYC data to mobile providers in order to obtain SIM Cards / Mobile Phones, this means that: 

  1. Mobile Phones that are already on databases as being connected to suspect usage / persons / organizations will immediately be detected by the system, and the relevant user’s account on the site immediately frozen.
     
  2. In the event of issues arising in respect of activity that is in contravention of any laws, the relevant Member can be located (whether they have uploaded their KYC documents to the site or not), because Members need to provide KYC data to their mobile providers in order to obtain SIM cards or Mobile Phones. 

 

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  1. Unique Inter TEL.mobi.mobi Account Numbers (ITAN)

Every Member is automatically assigned a unique ITAN number, which is linked to his/her account, mobile phone number, username, name and transactions. The ITAN system follows a very specific system which denotes Region and Country. The ITAN Numbers are used by the system to automatically:

  1. Monitor and prevent Top-up transfers to the wrong recipient.
     
  2. Refund Transfers to any person other than the account owner.
     
  3. Suspicious activity or unusual patterns on an account.

 

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  1. Unique Transaction Authentication Numbers (TAN)

Webtel.mobi generates and sends unique Transaction Authentication Numbers (TANs) to Members’ registered Primary Mobile Numbers by text/SMS for all important transactions, including joining the site, Top-up Transfer and Refund Transfers. If Members do not enter the unique TANs, no joining or transactions can or will be implemented. More information on Transaction Authentication Numbers can be obtained by clicking here

 

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  1. Multi-Factor Authentication (MFA)

The site uses Multi-Factor Authentication (MFA) for joining and for all important transactions on the site. The MFAs used on the site are:

  1. Unique personal email address and unique personal (unique) mobile phone number for signup (without which signup is not possible).
     
  2. Unique Username, Password, IWAN Number and a unique personal mobile phone number on which to receive a TAN for a Top-up Transfer (without which a Top-up Transfer is not possible).
     
  3. Unique Username, Password, Personal Name that corresponds with KYC Documentation and a unique personal mobile phone number on which to receive a TAN for a Refund Transfer (without which a Refund Transfer is not possible).

More information on Multi-Factor Authentication can be obtained by clicking here and here.

 

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  1. Multi-Step Transaction Verification (MTV)

The site uses Multi-Step Verification (MSV) for joining and for all important transactions on the site. The MSVs used on the site are:

  1. On joining, if the unique email bounces back or the unique TAN is not received and entered, joining is declined.
     
  2. On initiating a Top-up Transfer, if the Unique Username, Password and IWAN do not match, or if the unique TAN is not received and entered, the transaction is declined.
     
  3. On initiating a Refund Transfer, if the Unique Username, Password and Name on both the Transfer Request and the KYC Documentation do not match, or if the unique TAN is not received and entered, the transaction is declined.  

 

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  1. Combining CSCA + MNA + ITAN + TAN + MFA + MTV for Security

All important processes on the site require the successful completion of Multi-Factor Authentication (MFA) and Multi-Step Transaction Verification, which includes the receipt and inputting of one-off and unique mobile-delivered Transaction Authentication Numbers (TAN). This provides a high level of security in respect of Member and transaction authentication and security. A summary of these processes is:

 

Member / Telephone verification on Sign-up
Multi-Factor Authentication and Two-Step Verification by email and unique TAN number delivered by text message to the Member’s mobile phone. If the email is bounced the Member's account is immediately frozen by the system, and if the unique TAN is not entered the Member cannot use the system.

 

Top-up Transfer
Multi-Factor Authentication and Three-Step Verification by Username and Password, IWAN Number and unique TAN number delivered by text message to the Member’s mobile phone. If either the Username or Password is incorrect, or the recipient’s IWAN Number is incorrect, or the unique TAN is not entered, the Top-up Transfer cannot be implemented.

 

Refund
Multi-Factor Authentication and Three-Step Verification by Username and Password, Client Name and unique TAN number delivered by text message to the Member’s mobile phone. If either the Username or Password is incorrect, or the Recipient’s Name does not correspond with the name on the KYC Documentation, or the unique TAN is not entered, the Refund Transfer cannot be implemented. 

 

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  1. Company location in Secure Jurisdiction

The Company is situated in and operates its business from the States of Guernsey in the Channel Islands. Guernsey was selected as the Company’s principal place of Business because it seeks the highest levels efficiency in its business operations. It is one of only seven jurisdictions worldwide that could enable the Company to provide its services internationally at the same costs. In other jurisdictions, due to differences in inter-regional rates that would be applicable, the Company would have had to apply a variety of differing rates and conditions to its Members internationally – thereby significantly increasing complexity and also bringing about inequality of treatment of Members in different jurisdictions. By operating from Guernsey, the Company is able to provide the same rates worldwide, thereby providing an equal-opportunity service to all of its Members. Of the seven possible jurisdictions available, Guernsey has the joint highest ranking for stability, security, high levels of infrastructure and access to highly skilled professionals. Guernsey also voluntarily implements appropriate EU-standard legislation and applies all relevant international corporate and legal standards, which the Company conforms with. While Guernsey is sometimes thought of as being a zero tax jurisdiction, it in fact applies 0%, 10% and 20% corporate tax rates for companies – depending on the category of company. The rate applicable to the Company is described in the Global Social Responsibility section of this site. In summary, the key reasons for the company’s location in Guernsey are the stability, infrastructure and high corporate and legal standards; as well as an environment that helps maximize efficiency while simultaneously facilitating equal-opportunity treatment for the Company’s Members worldwide. More information on the Guernsey business / professional environment may be seen by clicking here

 

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  1. Members' Accounts in Secure Jurisdiction

All Members’ accounts on the Company’s site are legally deemed to be Guernsey-based accounts, and the activities that take place on and from the site are also all legally deemed to be Guernsey based (see the relevant Regulatory and Legal confirmation of this in the “Best Practice” section of this website). As such, all Company Members and their accounts enjoy the protection and peace of mind of being protected by the robust and transparent laws relating to business in Guernsey, and to the data protection, internet privacy laws, and all other relevant laws and regulations that are to be found in progressive and technologically / socially / legally / structurally advanced Free and Democratic 21st Century countries.

 

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  1. Anti Money Laundering  

  1. Overview

Anti Money Laundering is a critical factor in respect of international business, and Anti Money Laundering processes should always be strictly implemented and adhered to. For a top-level overview of what Anti Money Laundering entails, please click here.

 

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  1. The status of the Company

The Company is a Telephone Company.

 

It is not a Financial Services company, Money Transfer Company, Bank or any other related-services company. As such, it does not undertake – nor facilitate the undertaking of its users or Members or personnel – activities that would cause it to fall under the provisions that govern such business types or processes (see next sections).

 

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  1. The proactive stance of the Company

Even though the Company does not fall under the provisions that govern the previously-mentioned business types or processes, it has nevertheless taken the decision to apply a proactive stance that conforms with Best Practice in respect of Anti Money Laundering.

 

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  1. Only Clean and AML’d Funds In from Banks – Payment Gateway
  1. This subsection deals with inward transfers of funds to credit Members’ accounts via the Independent Payment Gateway.
     
  2. Just like every other Telephone Company in the world, the Company’s Members transfer funds to the company to credit their telephone accounts. Some companies do this on a post-paid basis, some on a prepaid basis and some on both a post-paid and a prepaid basis. The Company deals exclusively on a prepaid basis.
     
  3. The Company does not, can not and will not even accept into its telephony ecosystem or Members accounts any funds that have not already been through a thorough Anti Money Laundering process.
     
  4. This is because the Company does not, can not and will not accept any funds for payment for stored telephony credit that do not originate from BANKS.
     
  5. All Banks are required to apply rigorous Anti Money Laundering processes before accepting funds into bank accounts, and before transferring funds out of their bank accounts. Such funds have already undergone rigorous Anti Money Laundering checks by the professional Anti Money Laundering personnel at the bank.
     
  6. For a Member to load his or her account on the site via the Independent Payment Gateway that the Company utilises, he/she:
  • Has to make payment from funds that are already held in a bank account or transmitted via a bank – which means that the professional bank personnel would already have carried out the Anti Money Laundering checks that are required to be carried out; both on the Member, and on deposits of money into bank accounts.
  • Has to make a transfer from or via a bank – which means that the professional bank personnel would already have carried out the Anti Money Laundering checks that are required to be carried out; on both the Member, and on transfers of funds from a bank. 
  1. Moreover, these funds – which have already been through three Anti Money Laundering processes; once when the Member was KYC’d by the bank, once on the funds deposited at the bank, and once when the funds were transferred from or via a bank – are again subject to Anti Money Laundering checks when received by the Independent Payment Gateway. The Independent Payment Gateway carried out Anti Money Laundering checks on all funds passing through its gateway, and its receiving bank again carries out Anti Money Laundering checks on the funds received into its accounts.
     
  2. Only AFTER all of these Anti Money Laundering checks on funds have been completed do the funds arrive in the bank account from which they will be credited as stored credit to the Member’s account on the Company’s site.
     
  3. Thereafter, the Company additionally keeps a detailed record of all such inward transfers onto a Members account for a minimum of five years.

 

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  1. Only Clean and AML’d Funds In from Banks – Top-up Vouchers
  1. This subsection deals with crediting of Members’ accounts via the use of Top-up Vouchers.
     
  2. Just like every other Telephone Company in the world, the Company’s Members can purchase Top-up vouchers from third parties (Webtel.mobi VSMPs and/or Independent Agents) using cards or cash, and these Top-up Vouchers can be used to load stored credit onto their accounts on the site.
     
  3. As is standard practice in the Telephony Industry, these Independent Agents and/or Affiliates who will on-sell Top-up Vouchers are compelled to go through a KYC process by the Company (provision of KYC documents which the Company retains) in order to act as Independent Agents or VSMPs.
     
  4. The Top-up Vouchers are small denomination vouchers, up to a maximum of Euro 1000 per voucher (or equivalent in other currencies).
     
  5. However, even though the KYC-vetted Independent Agents and/or VSMPs may on-sell the Top-up Vouchers against payment in cards or cash, the Company itself does not accept cash.
     
  6. The Company does not, can not and will not even accept into its telephony ecosystem or Members' accounts any funds that have not already been through a thorough Anti Money Laundering process.
     
  7. This is because the Company does not, can not and will not accept any funds for payment for stored telephony credit that do not originate from BANKS.
     
  8. All Banks are required to apply rigorous Anti Money Laundering processes before accepting funds into bank accounts, and before transferring funds out of their bank accounts. Such funds have already undergone rigorous Anti Money Laundering checks by the professional Anti Money Laundering personnel at the bank.
     
  9. For a Top-up Voucher to be issued to an Independent Agent and/or VSMP for onward sale to a Member, the Independent Agent and/or VSMP has to pre-order and prepay for the Top-up Vouchers that he/she wants to on-sell through a Bank Transfer to the Company for the full amount of the Top-up Vouchers ordered.
     
  10. This means that the Independent Agent and/or VSMP has to:
  • Make payment from funds that are already held in a bank account or transmitted via a bank - which means that the professional bank personnel would already have carried out the Anti Money Laundering checks that are required to be carried out, on both the client, and on deposits of money into bank accounts.
     
  • Has to make a transfer from or via a bank – which means that the professional bank personnel would already have carried out the Anti Money Laundering checks that are required to be carried out, on both the Member, and on transfers of funds from a bank. 
  1. Only AFTER all of these Anti Money Laundering checks on funds have been completed do the funds arrive at the Company, after which Top-up Vouchers will be provided to the Independent Agent and/or VSMP.
     
  2. Thereafter, once the Top-up Vouchers have been provided to the Agent and/or VSMP, the Company keeps a record of:
  • All Top-up Vouchers, per unique Voucher Number and denomination, sent to each Independent Agent and/or VSMP.
     
  • The unique Webtel.mobi Member who purchases and uses the Top-up Vouchers and his/her use thereof.
     
  • For a minimum of five years.
  1. Moreover (and although it is not a consideration of, or for the Company), any funds in cash that the Independent Agent and/or VSMP may receive as a result of on-selling the Top-up Vouchers will have to be placed in that Independent Agent’s and/or VSMP’s bank account by them if they wish to utilize it without let or hindrance; as otherwise they themselves will be left holding cash, which cannot be utilized or freely dealt with by them due to stringent Anti Money Laundering laws in effect worldwide. Such funds, when placed into the Independent Agent’s and/or VSMP’s bank account, will again be subject to Anti Money Laundering review by the bank.

 

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  1. Stored Credit always Static in Account – No Transfers
  1. This subsection deals with the stored credit that exists within the Company’s own ecosystem of online Member accounts / Currency Wallets.
     
  2. The Webtel.mobi system (including the sites of its VSMPs – see the “Best Practice” section of this website) comprise a totally closed system, available to Members only.
     
  3. All stored credit within that system – which stored credit in Member accounts is a representation of the already-cleared funds in the bank account that they have been transferred to - is therefore also in the closed member system.
     
  4. The already-cleared funds that are represented by the ledger-entry reflection of stored credit in a Member’s online account are in fact all only in one bank account and sub accounts thereof.
     
  5. This means that even if and when stored credit amounts are sent from one Member’s stored credit account/wallet to another Member’s stored credit account/wallet within the closed system (a “Top-up Transfer”); the actual already-cleared funds themselves remain static in the same one bank account. It is only the ledger entries of stored credit in Member’s accounts that are altered. The funds themselves remain totally static in the same bank account where they entered, and do not move at all, even when the ledger entries of stored credit available per Member alters in the event of a “Top-up Transfer”. As such, no actual transfer or movement of the already-cleared funds takes place. The funds themselves remain static, and only the ledger entry / record of ownership of the funds is altered. In comparison, with other Telecoms Companies, Top-up Transfers entail actual transfers (actual physical movements of funds) – not merely ledger entry alterations with already-cleared clean funds remaining static in one account - and these can even be done by persons who are not members or clients of that Telecoms Company. Click on the links below for just a few of many thousands of examples:
  1. Similarly, when the stored credit values in the Member’s account/wallet are converted to other currencies, once again, no transfer or movement of actual funds takes place. The already-cleared funds are merely converted to other currencies, but remain static in sub-accounts (for different currencies) of the same account in which they were transferred, and in which they remain. Only the ledger entries of the currency which the Member owns in his/her stored credit are altered (and the Company utilizes the service of an appropriately licensed and regulated company to conduct such currency conversions).
     
  2. As such, for both “Top-up Transfer” and “Currency Conversions”, no funds transfer of any of the actual already-cleared funds occurs. Members’ ledger entries are merely altered to reflect the new ownership of these static funds, within a closed member system.
     
  3. Moreover, the Company additionally keeps a detailed record of all such Top-up Transfers between Members and Currency Conversions per Member for a minimum of five years.
     

 

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  1. AML Restrictions and KYC
  1. This subsection deals with movement of the already-cleared funds out of the Company’s closed environment and into Members' bank accounts (“Refund Transfers”) and for the future use of the Company’s Loyalty Card that will also be able to be used as a Prepaid Debit Card.
     
  2. The funds that a Member is entitled to – as represented by the ledger-entry record of the stored credit that he/she owns in their account/wallets – have already been previously and extensively checked according to Anti Money Laundering processes on multiple occasion – before they can even be recorded. This applies to ALL funds in the Webtel.mobi system. All such funds are therefore already verified as being clean and unencumbered.
     
  3. For several years, internationally and according to multiple accepted laws and treaties, owners of stored telephony credit or telephony post-paid accounts are able to utilize their telephony credit / accounts / wallets for – other than payment for their use of telephony services – payment for non-telephony goods and services. This was initially only done via Premium rate text messages, but since 2015 has included direct carrier billing and other forms of direct payment at retailers. Although there are thousands of companies and merchants and millions of clients who already participate in mobile payments, a small selection thereof, as examples, appear at the links below:
  1. Other than this, all Members of Webtel.mobi – and of all and any Telephony Companies, and all and any other companies that provide goods or services to the public – are entitled to request a refund of any stored credit that they may have on their accounts. It is a legal obligation of Webtel.mobi and all or any other Telephony or other companies to refund clients stored credit if so requested.
     
  2. As such, because the funds in the Webtel.mobi closed online system are already cleared funds, which are static in one bank account from arrival and which never move, and which belong to the Members (according to the ledger-entry on the Members’ accounts / wallets recording the amount of funds owned by the Member and the Member is entitled to request a refund of his or her stored credit which Webtel.mobi is legally obliged to refund, and as Webtel.mobi is a telephony company and not a financial services company; Webtel.mobi is in fact able to implement the refund of these already-cleared and unrestricted funds to the Member immediately.
     
  3. The above notwithstanding, and because Webtel.mobi has taken a Best Practice approach towards good Corporate Governance, strongly supports Anti Money Laundering laws and processes, and because Members’ accounts may have altered due to Top-up Transfer between Members’ accounts, Webtel.mobi has, voluntarily and proactively: Applied and implemented a robust Anti Money Laundering Regime in respect of Refund Transfers.
  • Which includes a requirement for Members to provide correct and verified KYC documentation, according to international AML Best Practice, without which they cannot use the Refund Transfer facility. This is even though the Company is already in possession of the Member’s verified personal Mobile Phone Number, which means that the Member has already previously submitted KYC documentation to get the mobile SIM Card or Mobile Phone.
     
  • And which restricts Refund Transfers to only being able to be made to a bank account in the name of the Member making the Refund Transfer (as confirmed and verified by the KYC documentation).
     
  • And which includes the application of limits on the amounts that can be transmitted in a Refund Transfer, unless additional documentation is provided, replicating the requirements of international AML Best Practice.
     
  1. Moreover, the Company additionally keeps a detailed record of all such Refund Transfers by Members for a minimum of five years.
     
  2. Over and above these procedures, the Company’s system also automatically monitors all Member accounts and activities at all times, for the combined safety and security of the Members, the company and for corporate security reasons (which include AML and other suspicious activity reasons).
     
  3. The Company can and will, therefore, be able to detect – and will deny the use of the Refund Transfer facility to – any individual or entities on any Prohibited or Sanctioned Persons / Organizations list internationally. Similarly, the Company can and will detect any unusual activity and/or transactions and/or suspicious activities on or from Members’ accounts. If such activities present the characteristics of suspicious transactions, the account will be frozen immediately, and the Member contacted. If a satisfactory explanation is unable to be provided by the Member, the Company will refer the matter to relevant law-enforcement organizations that deal with AML and related matters, and will take such steps as recommended by them before (and if) unfreezing the suspicious account. A list of some of these law-enforcement organizations can be seen by clicking here.

 

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  1. An extremely safe system
  1. This subsection deals with Anti Money Laundering matters, and with security on the Webtel.mobi system in general.
     
  2. The Company’s system is unique and unrivalled and due to its construction, processes and method of operation, it is one of the most secure and sophisticated systems that is possible to exist to guard against Money Laundering, Fraud or any other unwanted activity. There is no other system like it internationally, at all.
     
  3. This is because it is:
  • A unitary system.
     
  • With every single one of its functionalities interconnected.
     
  • Accessible from every country and territory in the world.
     
  • But with all its Member and their activities legally being Guernsey-based.
     
  • With Multi-Factor Authentication being done by Members just to join (which means an effective and de-facto KYC from the start, as mobile SIM card / phone owners are already KYC’d when obtaining those items).
     
  • And all funds coming into, residing in, and leaving from only one location.
     
  • With every single activity being implemented, controlled and recorded by only one unitary system. 
     
  1. As an illustration, if one examines other entities that deal with clients globally, and the challenges that they face with Anti Money Laundering or security-related matters, the following examples illustrate the compelling nature of the Company’s unrivalled system in comparison
     
  2. Other Telecoms Companies:
    Other Telecoms Companies that have not been specifically built and structured in the manner that Webtel.mobi has can only provide their services in and to very limited markets. This cannot be altered. They are also only able to provide limited services in terms of carrier billing or mobile payments due to the limitations of their physical and corporate structuring, and therefore have to rely on partnerships and co-operative agreements with multiple other companies to implement such mobile billing / mobile payments / direct carrier billing / other activities. Effective Money Laundering and/or criminal activities rely on either anonymity or what is known as “layering”, whereby a transaction passes through multiple entities so that its provenance / origin and destination become obscured. If there are multiple entities involved in and with any transaction, the risk of this “layering” being able to occur is heightened. In the case of Webtel.mobi, all funds enter it from one point only, all funds remain static in it only, and all funds can only leave from it. It is the sole entity providing, managing and controlling all services on its platform – in-toto – and its system can therefore permanently monitor all activities and transactions, on or via all of its services, in a totally connected and transparent manner, at all times from inception to completion, totally. Moreover, all of its Members are – other than the actual KYC requirements in terms of Refund Transfers – all de-facto KYC’d because of their joining through the Multi-Factor Authentication process via email and the texting of a TAN to their Primary Mobile Phone numbers (which they have already undergone KYC to get from their provider). As such, in respect of security systems in comparison to other Telecoms Companies, besides the fact that Webtel.mobi’s telephony services are globally unrivalled, all aspects related to integrated security (including AML) and other services are also unrivalled – making it an extremely secure system in all respects, and one which cannot be rivalled by other Telecoms Companies.
     
  3. Banks:
    Webtel.mobi is a Telephone company and not a Bank, and it does not provide Banking services or services related to Banking services. However, as banks are entities that have to apply AML procedures, this example is therefore only to illustrate the comparatively robust nature of the Webtel.mobi AML and security flow and capabilities. If one takes a branch of a Bank, it will have hundreds or thousands of clients with accounts. Those clients have been KYC’d. However, funds can be transferred into those accounts from other Banks and Money-Transfer companies, which, in total, will comprise hundreds of thousands of other Bank branches / Money-Transfer companies internationally (and each one of those hundreds of thousands of other Bank branches / money transfer companies will have hundreds or thousands of client accounts each). Moreover, the clients of the Bank branch can transfer funds to any one of the client accounts in these hundreds of thousands of other Bank branches internationally. Added to this, clients of the Bank branch - or of the hundreds of thousands of other Bank branches that can transfer funds into the Bank branch – can make deposits in cash; and clients of the Bank branch may also withdraw funds in cash. The security / AML personnel of the Bank branches are therefore faced with the task of attempting to monitor transactions that have tens-of-millions (if not hundreds of millions) of potential configurations. This is difficult to do – particularly as the Bank branch will not have KYC’d the (potentially hundreds of thousands to millions of) recipients of funds that are transferred out from configurations, the potential for “layering” is heightened. In the case of Webtel.mobi, however, there is only one entry point for funds, only personnel who are known to / members of Webtel.mobi are allowed to participate in any actions on or with Webtel.mobi, and there is only one exit point – directly to a KYC’d Member whose activities on the site have been constantly monitored. Moreover, Webtel.mobi neither accepts nor disburses cash. As such, it can be seen that the Webtel.mobi system, in comparison, is robust in terms of its potential to provide excellent security in terms of AML and other security requirements.
     
  4. Money Transfer Companies:
    Webtel.mobi is a Telephone company and not a Money-Transfer Company, and it does not provide Money-Transfer services or services related to Money-Transfers. However, as Money Transfer Companies have to apply AML procedures, this example is therefore only to illustrate the comparatively robust nature of the Webtel.mobi AML and security flow and capabilities. Money Transfer Companies use banks to carry out the actual transfers of funds, and furthermore accept and disburse a large amount of their business using cash. As such, the same considerations in respect of complex and very large potential configurations in respect of AML checks that apply to Banks apply to Money Transfer Companies, and the same advantages that the Webtel.mobi system has in terms of system / process / flow comparison with Banks in terms of AML considerations exists.
     
  5. Debit Card / Credit Card Companies:
    Webtel.mobi is a Telephone company and not a Debit or Credit Card Company. However, as Debit and Credit Card Companies have to apply AML procedures, this example is therefore only to illustrate the comparatively robust nature of the Webtel.mobi AML and security flow and capabilities. Credit and Debit Card Companies use banks to carry out the actual holding of funds that are used via the Credit or Debit Cards, and disbursement of cash using the Credit or Debit Cards. As such, the same considerations in respect of complex and very large potential configurations in respect of AML checks that apply to Banks apply to Credit and Debit Card Companies, and the same advantages that the Webtel.mobi system has in terms of system / process / flow comparison with Banks in terms of AML considerations exists.
     
  6. Fintech / Mobile Payments companies:
    Webtel.mobi is a Telephone Company and not a Fintech or Mobile Payments Company. However, as most Fintech and Mobile Payments Companies have to apply AML procedures, this example is therefore only to illustrate the comparatively robust nature of the Webtel.mobi AML and security flow and capabilities. Almost all Fintech and Mobile Payment companies that deal with mobile or online wallets / payments / accounts / money transfers, and which are not Banks or Credit / Debit Card companies or Telephone Companies themselves, are in reality de-facto white-labels / aggregators / marketers / feeders of/for either Banks, Credit / Debit Card Companies, or Telephone Companies. The majority of such companies are no different to Webtel.mobi’s VSMPs, in that they have no business flow, process or model of their own in respect of the execution of any of the primary services which they offer. Instead, they have to piggyback off the services of those companies, or offer the services of those companies, only white-labelling the ability to access those services (for example, by loading Credit / Debit cards onto a mobile application – which is the digital version of putting the same Credit or Debit Card issued by a Credit or Debit Card Company into one's pocket). Consequently, whatever such a Fintech or Mobile Payments company may or may not be capable of, when it comes to AML and security considerations, the same complexities that apply to other Banks / Money Transfer Companies, Credit or Debit Card Companies / Telephone Companies apply to them (because they use the facilities and infrastructure of those entities), and the robust advantages of Webtel.mobi’s system in comparison to those systems has already been clearly illustrated.
     
  7. As such, other than the previously-mentioned security aspects and the previously-mentioned Anti Money Laundering aspects, the Webtel.mobi unitary system is in and of itself – and because it is a unitary system with no third-party reliance - an additional tool in the Anti Money Laundering / security process.

 

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  1. Summary

The Company takes the matter of Security – for its Members, for Corporate Security (including AML) and its own Company security – very seriously, has planned and effectively implemented Best Practice structures, procedures, processes and flows to maintain the highest and best security profile possible for all persons and entities that interact with the Company in any way.

 

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