Governance, Risk and Compliance Statement:

Uncompromising Integrity. Global Standards. Secure Financial Ecosystem.

At Whish Money, trust is the currency we value most. As a leading fintech licensed and regulated by the Banque du Liban (BDL) (License No. 42/5/19), we are fundamentally committed to protecting our customers, partners, and the integrity of the global financial system.

Our Governance, Risk, and Compliance (GRC) framework is not merely a requirement—it is a proactive defense system designed to ensure financial security, regulatory adherence, and operational resilience across all our market.

1. Regulatory Governance & Licensing

Whish Money operates under a rigid legal framework, ensuring full accountability to national and international authorities.

  • Primary Regulator (Lebanon): We are a licensed financial institution regulated by Banque du Liban (BDL) under License No. 42/5/19. We strictly adhere to all Basic and Intermediate Circulars governing electronic payments, cross-border transfers, and digital wallets.
  • Global Expansion & Compliance: Validating our commitment to international standards, Whish Money, through dedicated entity, has secured licensure as a Money Services Business (MSB) in Canada, demonstrating our ability to meet North American compliance benchmarks. We are actively aligning our frameworks with regulatory requirements in the US, UK, andEU as part of our global roadmap.
  • U.S. Licensing Disclosure: Certain services made available through Whish Money are supported by payment processing delivered by Veem Payments Inc., a licensed money transmitter under applicable U.S. state laws and a FinCEN-registered Money Services Business. Additional information is available in Veem’s Payment Processing & Licensing Disclosure
  • Audit & Oversight: Our operations are subject to regular independent audits. Our Board of Directors maintains direct oversight of the compliance function, ensuring that risk management is independent of revenue objectives.

2. Financial Crime Prevention (AML/CFT)

We enforce a Zero-Tolerance Policy regarding Money Laundering (ML), Terrorist Financing (TF), and Sanctions Evasion. Our program is built on the FATF Recommendations and the Wolfsberg Group Principles.

  • Global Sanctions Screening: Every transaction—domestic or cross-border—is screened in real-time against major global watchlists, including:
    • OFAC (US Treasury)
    • UN Security Council Consolidated List
    • EU Consolidated List
    • HMT (UK)
    • SIC (Special Investigation Commission) Lebanon local lists.
  • KYC & Lifecycle Management: We employ a dynamic Know Your Customer (KYC) model. Beyond initial identity verification (Government ID, Biometrics), we perform ongoing Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk profiles or politically exposed persons (PEPs).
  • Institutional Cooperation: We maintain an open, cooperative channel with the Special Investigation Commission (SIC) and other relevant Financial Intelligence Units (FIUs), filing Suspicious Transaction Reports (STRs) proactively when high-risk indicators are detected.

3. Technology & Risk Architecture

We do not rely solely on manual review. Our compliance is powered by an advanced technological infrastructure.

  • AI-Driven Surveillance: Our proprietary transaction monitoring engine uses machine learning to detect behavioral anomalies, structuring (smurfing),and complex fraud patterns in milliseconds.
  • The "Three Lines of Defense" Model:
    1. Operational Controls: Automated system limits (velocity, volume, and value caps) embedded at the point of transaction.
    2. Risk Management: A dedicated compliance team that reviews flagged activities and manages regulatory change.
    3. Internal Audit: Independent assurance that tests the effectiveness of our controls.

4. Trusted Global Ecosystem

Our compliance maturity is validated by our integration with the world’s leading financial networks. Whish Money has passed the rigorous due diligence of Tier-1 global partners and independent audit firms. These entities confirm that our control environment meets the highest international standards for counter-party risk.

5. Data Privacy & Cybersecurity

We treat customer data as a critical asset. Our cybersecurity framework aligns with global best practices to ensure data sovereignty and integrity.

  • Encryption: All sensitive data is encrypted at rest and in transit.
  • Access Rights: Strict role-based access controls ensure that customer data is accessible only to authorized personnel for legitimate business purposes.
  • Transparency: We are committed to transparency regarding how data is collected, used, and stored, adhering to applicable data protection laws in every jurisdiction where we operate.

Consumer Rights

Complaints Handling Policy

At Whish Money (“we”, “us”, “our”), we are committed to providing high-quality services and ensuring a fair, transparent, and efficient resolution of customer complaints.

For the purpose of this policy, a complaint is any expression of dissatisfaction, whether formal or informal, verbal or in writing, relating to our services, products, actions, or omissions, which requires a response or resolution.

The complainant (“you”, “your”) refers to any customer or individual who submits acomplaint to Whish Money.

How to Submit a Complaint 

You may submit a complaint through any of the following channels: 

  • Email: feedback@whish.money 
  • Website or App: Through our available contact options 
  • Customer Support: Via phone or WhatsApp +961 01 788 999 / +961 03 115 111 
  • In Person: At any Whish Money branch 

Please include your contact details and a clear description of your concern. 

 

Our Commitment 

  • We will acknowledge receipt of your complaint within 1 business day. 
  • We aim to provide an initial update within 5 business days. 
  • We will review your complaint and notify you of the outcome of the complaint handling process within fifteen (15) days at most from the date on which the complaint is received
  • Where the complaint relates to services provided by third-party service providers, partners, or external entities, the review and resolution of such complaint may depend onthe response, cooperation, and processing timelines of the concerned third party.In such cases, Whish Money will follow up with the relevant party and keep you informed, where applicable.

Resolution & Escalation 

We will provide you with a clear response outlining our findings and any action taken. 

If you are not satisfied with the response provided, you may request an escalation of your complaint for further assessment and review in accordance with Whish Money’s internal procedures.

 

Confidentiality & Fair Treatment 

All complaints are handled confidentially and your personal data is protected inaccordance with applicable laws and regulations. 

Submitting a complaint will not affect yourrelationship with Whish Money or the services you receive. 

 

Continuous Improvement 

All complaints are treated seriously and reviewed to improve our services and customer experience. 

 Consumer Protection

At Whish Money (“We” , “us”, “our”) , we are committed to protecting our customers’ rights, funds, and personal data, and to delivering services that are fair, transparent, and secure.

Who is a Customer

For the purpose of this policy, a customer (“You”, “your”) is any individual who uses or has used Whish Money services, through any channel, including the mobile application, website, branches, or authorized agents.

Our Commitment

We place customer protection at the core of our operations. We are committed to:

  • Fair Treatment: Treating all customers fairly, respectfully, and without discrimination
  • Transparency: Providing clear, accurate, and timely information on our products, services, fees, and terms
  • Informed Consent: Ensuring customers understand and agree to services before use
  • Safeguarding of Funds: Protecting customer funds through secure and regulated mechanisms
  • Data Protection: Processing and protecting personal data in accordance with applicable laws and regulations
  • Responsible Practices: Preventing misleading practices, overcharging, or unfair treatment

 

Your Rights

As a customer, you have the right to:

  • Receive clear, accurate, and accessible information about our services
  • Be charged only disclosed and transparent fees
  • Have your funds handled securely and responsibly
  • Have your personal data protected and request access, correction, or deletion
  • Submit complaints and receive a fair, timely, and transparent resolution
  • Be treated with fairness, respect, and professionalism at all times

Customer Awareness & Support

We are committed to promoting customer awareness by providing clear information and guidance to help you understand our services, associated risks, and how to use our products safely.

 

Customers Requiring Additional Support

We are committed to providing appropriate support,  to the best of our ability, to customers who may require additional assistance due to specific circumstances. Where applicable, additional care and assistance may be provided to ensure fair access to our services and to protect such customers from potential risks.

 

Protection of Funds & Transactions

We implement strict safe guards to ensure the security of customer funds and transactions, including:

  • Segregation of customer funds from company operational funds
  • Secure and encrypted transaction processing systems
  • Strong customer authentication measures
  • Continuous transaction monitoring to detect and prevent unauthorized activity
  • Real-time notifications for transactions, where applicable

 

Regulatory Compliance & Restrictions

As an electronic payment services provider licensed and regulated by Banque du Liban, Whish Money complies with all applicable laws and regulations, including AML/CFT andsanctions requirements.

Certain services or transactions may be restricted, declined, or subject to additional verification where required by law, best practices or regulatory authorities.

Account and Transaction Issues

Should you identify any issue relating to your account or any transaction, you are encouraged to notify Whish Money promptly. We will investigate such cases and take appropriate action in accordance with applicable regulations and internal procedures.

 

Data Privacy & Confidentiality

We are committed to protecting your personal data in accordance with applicable laws and regulatory requirements.

We ensure that:

  • Personal data is collected only for legitimate and specified purpose
  • Data is protected against unauthorized access, misuse, or disclosure
  • Data is not shared with third parties without appropriate legal basis or consent

You remain responsible for maintaining the confidentiality and security of your credentials, including your password, PIN,and any authentication details. Please ensure that this information is kept secure and not shared with any third party.

You are also expected to provide accurate information and promptly report any unauthorized activity related to your account.

Fees & Transparency

We are committed to full transparency in our pricing:

  • All applicable fees and charges are clearly disclosed before transaction confirmation
  • Customers are provided with a clear summary of transaction details
  • Whish Money posts, on its website and electronic application, all commissions and fees collected for any type of operation or service it provides. Customers may also refer to the  Fees & Commissions page available at: https://www.whish.money/fees-commissions
  • We do not apply hidden fees or undisclosed charges

 

Agents & Third Parties

All authorized agents and partners are required to comply with Whish Money’s consumer protection standards, including:

  • Fair and respectful treatment of customers
  • Full disclosure of fees and charges
  • Proper handling of transactions and customer information

We actively monitor compliance and take corrective action where necessary.

 

Complaints & Redress

We are committed to handling all complaints fairly, efficiently, and free of charge.

If you are not satisfied with any of our services

  • You may submit a complaint through  our available channels
  • Your complaint will be reviewed and resolved in a timely and transparent manner, in accordance with our Complaints Handling Policy.

Submitting a complaint will not affect your access to our services or the quality of service you receive.

 Contact Us 

  • Website: www.whish.money 
  • Email: feedback@whish.money 
  • Phone / WhatsApp: +961 01 788 999 / +96103 115 111