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Chris · 09-24-2010, 03:24 PM

1) Choice Bank of Belize - cards are issued using their charter w/Mastercard and administered by Metavante then? (plastic issuance, customer support, et al)?

No, Choice bank is the issuing bank only. We take care at paxum of the network integration API with the MC network through approved gateway providers, customer service is done by Paxum as well. Plastic printing is done by a third party MC accredited company.

2) To clarify the funds storage method, funds stored at the wallet are at Montreal Bank and funds to be made available to individual cardholders are pushed to Choice Bank of Belize into the Paxum, Inc. account. So a daily sweep would occur from the wallet to Choice Bank of all funds requested released to the card product daily?

Balances at both the wallet and the card are maintained by Paxum's internal systems. At no time is there a report to either financial institution of the value of individual wallets or funds available to cardholders via the card product? There's simple a "gross balance" at each account representing the value of the wallets and the cards?

no, all funds on cards are deposited in real time on the cards from your ewallet to the card account. you do not have to worry about how our internal transfers take place between us and the bank, your money is instant. The bank knows at all times along with MC how much money is on the card as the card provided is a FULL mastercard with an individual account associated (invisible to the user) but once the money is deposited on the card it leaves our wallet and we no longer have access to it unless you transfer it back from the card to the ewallet account.

3) Can you give us more information on how the KYC is handled? Is that transmitted to the bank prior to card issuance for verification or is Paxum the verifying entity? If Paxum is the verifying entity, how does the bank conduct its due diligence to ensure compliance prior to issuing the Mastercard product?

MC does the compliance through automated ID number screening and manual on a case by case if needed. Paxum does the DUE diligence by hand to all accounts prior to issuing a card.

Are the cards issued directly to the individual program participants by the bank/platform? Or is Paxum handling card issuance directly? In either event, once KYC is complete, is the card embossed with the owner name and magstriped with cardholder detail or is it a generic?

Paxum is handling the card issuance directly as we have a FULL MC license. we are not some resellers of some bank cards. it is a full MC card from PAXUM Inc. and it has the card number and name embossed with the ownerss name. It is again a full MC just like the ones issued by your local chartered bank, it is NOT an electronic crippled card.

4) Just to clarify, transfers that occur between affiliate programs and webmasters (as an example) are done internal to Paxum's operating systems and are in effect an internal wallet to wallet transfer. Limits and controls on these transactions or internal to your network. Funds availability demands to the cards are pushed from the "wallet" account to the "card" account (Paxum, Inc), and individual cards can access their balances (up to $2500 per day) based on a funding report you provide the platform that essentially says: "Card X for Paxum, Inc. has a total available draw down of, say $7,000 with a daily limit of $2,500."

transfers that occur inside the ewallet are managed by Paxum limits internally. Transfer and funds on MC are managed by Master Card and the limits are imposed and enforced by MC. each card is a FULL account with MC meaning that the money is deposited on the card and sits on the card. As per MC imposed limits you can have a maximum balance of $10,000.00 at any given time on the card and $2500 limit per day for withdawals/depostis/transfers/etc. if you make a transaction every day you will withdraw for example 30 days times 2500.00 per day for $75k a month.

5) There is a .pdf of the CBB (Central Bank of Belize) guidelines regarding AML and Combating Financial Terrorism available. I would assume that Paxum is adhering to these based on that statement.

we comply with every law and regulation imposed of course. if you plan to commit fraud or to use the card for any illegal activity we kindly ask you not to use the card. By asking all those technical/legal questions I hope you are not trying to circumvent the law or abuse the system in any way.

6) Thank you for that answer. The cards are not individual accounts, but are attached to the Paxum, Inc. account as the owner of the deposit then based on your response. Choice Bank is, of course, not subject to the FDIC but the CBB does utilize the U.S. Treasure OFAC (Office of Foreign Asset Control) "best practices" concerning money transfer businesses according the documentation reference above. Are these transactions subject to that scrutiny since all transfers are done internal to Paxum's system and all funds are held by one entity, Paxum?

As per my answer above, we comply with all regulations imposed by MC for the card part of paxum and by for the ewallet part to our own internal rules set up by either Canadian or international law. Once again without being rude but we will not disclose those internal rules and flags raised in detail as not to help in any way people trying to circumvent or abuse the system. If you are legit and try to use the cards you do not have to worry about all those. if you plan to commit any criminal activity or anything wrong be sure we will comply with all law enforcement agencies and will not cover you in any way. Once again dont use Paxum if you try to do anything illegal (fraud, gambling, terrorism, money laundering, etc) as we will close down your account and share the information with the authorities if needed. we have 0 tollerance for illegal activity.

7) & 8) Thank your for clarifying that the bank (and I assume the card platform) know the nature of the client base and are only restricting gambling. With regards to your statement, yes, an initial assessment by the bank and Mastercard would have been necessary to approve the launch of the service. A comprehensive published audit of the company's operations, risk management and financial strength on an annual or, better yet, a semi-annual basis would seem to be a prudent step since Paxum, if working properly would be holding a significant amount of 3rd party funds for your clients.

unfortunately we cannot make public our audits in any way. we are a privately held company and there are only few people having access to that for privacy reasons. among them are the accountants and lawyers that work for us along with the investors backing the project financially. But you will understand that we cannot disclose those audits as it involves numbers that are not to be public.

09-24-2010, 03:24 PM
Chris Too lazy to set a custom title Industry Role: Join Date: May 2003 Location: icq: 71462500 Skype: Jupzchris Posts: 27,880	1) Choice Bank of Belize - cards are issued using their charter w/Mastercard and administered by Metavante then? (plastic issuance, customer support, et al)? No, Choice bank is the issuing bank only. We take care at paxum of the network integration API with the MC network through approved gateway providers, customer service is done by Paxum as well. Plastic printing is done by a third party MC accredited company. 2) To clarify the funds storage method, funds stored at the wallet are at Montreal Bank and funds to be made available to individual cardholders are pushed to Choice Bank of Belize into the Paxum, Inc. account. So a daily sweep would occur from the wallet to Choice Bank of all funds requested released to the card product daily? Balances at both the wallet and the card are maintained by Paxum's internal systems. At no time is there a report to either financial institution of the value of individual wallets or funds available to cardholders via the card product? There's simple a "gross balance" at each account representing the value of the wallets and the cards? no, all funds on cards are deposited in real time on the cards from your ewallet to the card account. you do not have to worry about how our internal transfers take place between us and the bank, your money is instant. The bank knows at all times along with MC how much money is on the card as the card provided is a FULL mastercard with an individual account associated (invisible to the user) but once the money is deposited on the card it leaves our wallet and we no longer have access to it unless you transfer it back from the card to the ewallet account. 3) Can you give us more information on how the KYC is handled? Is that transmitted to the bank prior to card issuance for verification or is Paxum the verifying entity? If Paxum is the verifying entity, how does the bank conduct its due diligence to ensure compliance prior to issuing the Mastercard product? MC does the compliance through automated ID number screening and manual on a case by case if needed. Paxum does the DUE diligence by hand to all accounts prior to issuing a card. Are the cards issued directly to the individual program participants by the bank/platform? Or is Paxum handling card issuance directly? In either event, once KYC is complete, is the card embossed with the owner name and magstriped with cardholder detail or is it a generic? Paxum is handling the card issuance directly as we have a FULL MC license. we are not some resellers of some bank cards. it is a full MC card from PAXUM Inc. and it has the card number and name embossed with the ownerss name. It is again a full MC just like the ones issued by your local chartered bank, it is NOT an electronic crippled card. 4) Just to clarify, transfers that occur between affiliate programs and webmasters (as an example) are done internal to Paxum's operating systems and are in effect an internal wallet to wallet transfer. Limits and controls on these transactions or internal to your network. Funds availability demands to the cards are pushed from the "wallet" account to the "card" account (Paxum, Inc), and individual cards can access their balances (up to $2500 per day) based on a funding report you provide the platform that essentially says: "Card X for Paxum, Inc. has a total available draw down of, say $7,000 with a daily limit of $2,500." transfers that occur inside the ewallet are managed by Paxum limits internally. Transfer and funds on MC are managed by Master Card and the limits are imposed and enforced by MC. each card is a FULL account with MC meaning that the money is deposited on the card and sits on the card. As per MC imposed limits you can have a maximum balance of $10,000.00 at any given time on the card and $2500 limit per day for withdawals/depostis/transfers/etc. if you make a transaction every day you will withdraw for example 30 days times 2500.00 per day for $75k a month. 5) There is a .pdf of the CBB (Central Bank of Belize) guidelines regarding AML and Combating Financial Terrorism available. I would assume that Paxum is adhering to these based on that statement. we comply with every law and regulation imposed of course. if you plan to commit fraud or to use the card for any illegal activity we kindly ask you not to use the card. By asking all those technical/legal questions I hope you are not trying to circumvent the law or abuse the system in any way. 6) Thank you for that answer. The cards are not individual accounts, but are attached to the Paxum, Inc. account as the owner of the deposit then based on your response. Choice Bank is, of course, not subject to the FDIC but the CBB does utilize the U.S. Treasure OFAC (Office of Foreign Asset Control) "best practices" concerning money transfer businesses according the documentation reference above. Are these transactions subject to that scrutiny since all transfers are done internal to Paxum's system and all funds are held by one entity, Paxum? As per my answer above, we comply with all regulations imposed by MC for the card part of paxum and by for the ewallet part to our own internal rules set up by either Canadian or international law. Once again without being rude but we will not disclose those internal rules and flags raised in detail as not to help in any way people trying to circumvent or abuse the system. If you are legit and try to use the cards you do not have to worry about all those. if you plan to commit any criminal activity or anything wrong be sure we will comply with all law enforcement agencies and will not cover you in any way. Once again dont use Paxum if you try to do anything illegal (fraud, gambling, terrorism, money laundering, etc) as we will close down your account and share the information with the authorities if needed. we have 0 tollerance for illegal activity. 7) & 8) Thank your for clarifying that the bank (and I assume the card platform) know the nature of the client base and are only restricting gambling. With regards to your statement, yes, an initial assessment by the bank and Mastercard would have been necessary to approve the launch of the service. A comprehensive published audit of the company's operations, risk management and financial strength on an annual or, better yet, a semi-annual basis would seem to be a prudent step since Paxum, if working properly would be holding a significant amount of 3rd party funds for your clients. unfortunately we cannot make public our audits in any way. we are a privately held company and there are only few people having access to that for privacy reasons. among them are the accountants and lawyers that work for us along with the investors backing the project financially. But you will understand that we cannot disclose those audits as it involves numbers that are not to be public. __________________ [email protected]