Duty to investigate

We actively contribute to Anti Money Laundering (AML) and Terrorist Financing 

Bill Kill is a payment institution, cf. section 2-10 of the Act on financial institutions and financial groups 2015. Pursuant to section 13-5 of Act of 17 April 2015 no. 17 on financial undertakings ("Ffl"), Bill Kill has appropriate guidelines and routines for identifying, managing, monitoring and report the risk the company is, or may be, exposed to.

Bill Kill has a duty to investigate. The duty to investigate arises when we uncover conditions that may indicate that invoices / funds have
connection to a criminal act, cf. Hvvl § 25 (1). According to Circular 8/2019, the threshold for conducting examinations is low. Any indication may in principle be sufficient. Pursuant to Hvvl § 25 (2), "further" investigations shall be carried out if circumstances are discovered that deviate from knowledge of the customer, the purpose of the customer relationship and the intended nature, cf. Hvvl § 25 (2), or if a transaction from an invoice:

• seems to lack a legitimate purpose,
• is unusually large or complex,
• is unusual in relation to the customer's known business or personal transactions,
• carried out to or with a customer from a country that does not have satisfactory measures against money laundering or
terrorist financing, or
• otherwise has an unusual character.

If circumstances are identified that may indicate that funds are related to money laundering or terrorist financing, and that further investigations provide grounds for suspicion pursuant to Hvvl. § 26, it will be reported to Økokrim (National Authority for Investigation and Prosecution of Economic and Environmental Crime) .