AML POLICY OF PAYSZONE LTD

This Anti-Money Laundering (AML) policy outlines the procedures, measures, and responsibilities for preventing, detecting, and reporting money laundering and terrorist financing activities within the operations of Payszone ltd a high-risk payment service provider. The Company is committed to complying with all relevant local and international AML laws and regulations to protect the financial system and maintain the integrity of its services.

• Prevent and detect money laundering (ML) and terrorist financing (TF) activities.
• Ensure compliance with applicable AML regulations and best practices.
• Identify and assess potential risks related to money laundering and terrorist financing.
• Establish clear procedures for reporting suspicious activities to relevant authorities.
• Protect the Company’s reputation and financial stability.

This AML policy applies to all operations, employees, agents, and affiliates of Payszone ltd, particularly those involving high-risk transactions and customer profiles. The policy also extends to third parties involved in providing payment services, including but not limited to vendors, contractors, and business partners.

• Money Laundering (ML): The process of concealing the origins of illegally obtained money, typically through transfers or transactions involving legitimate businesses.
• Terrorist Financing (TF): The process of providing financial support to individuals or organizations engaged in terrorism.
• High-Risk Customer: A customer whose transaction profile, business, or geographic location presents a higher risk for money laundering or terrorist financing.
• Politically Exposed Person (PEP): An individual who holds or has held a prominent public function, such as a government official, senior executive, or senior political party figure.

The Company will perform ongoing risk assessments to identify and evaluate high-risk customers, transactions, and geographic areas. Factors considered in assessing risk include:

• Customer type and business activities.
• Geographic location, including countries or regions subject to sanctions or with weak AML enforcement.
• The nature and complexity of transactions, including large or unusual transfers.
• Whether the customer is a PEP or related to a PEP.

The Company will perform Customer Due Diligence (CDD) on all customers to verify their identity and assess the potential risk of money laundering or terrorist financing. The level of due diligence will be based on the assessed risk profile:

• Standard CDD: For low-risk customers, basic identification information is sufficient (e.g., name, address, date of birth, and government-issued ID).
• Enhanced Due Diligence (EDD): For high-risk customers (e.g., PEPs or customers from high-risk jurisdictions), additional documentation and verification are required, including the source of funds and the purpose of the transactions.

The Company will ensure that it:

• Collects comprehensive identification data for each customer before opening an account or processing any transactions.
• Verifies the identity of each customer through reliable and independent sources.
• Continuously monitors customer activities and transactions for inconsistencies or suspicious patterns.
• Updates customer information regularly, especially if their risk profile changes.

The Company will implement automated transaction monitoring systems to detect and report suspicious activities, including:

• Unusual or large transactions that are inconsistent with a customer's known business or personal activities.
• Rapid movement of funds to or from high-risk jurisdictions.
• Transactions that appear structured to avoid regulatory reporting thresholds.

If any employee, agent, or partner identifies suspicious activity, they must immediately report it to the designated AML Compliance Officer (AMLCO). The Company will file Suspicious Activity Reports (SARs) with the appropriate regulatory or law enforcement authorities, as required by law.

The Company will designate an AML Compliance Officer (AMLCO) responsible for:

• Overseeing the implementation of the AML program.
• Conducting training and awareness programs for employees.
• Ensuring compliance with all applicable AML laws and regulations.
• Liaising with regulatory authorities and reporting suspicious activities.

The Company will provide ongoing AML training to all employees, particularly those involved in customer onboarding, transaction monitoring, and compliance roles. The training will include:

• The basics of money laundering and terrorist financing.
• Company policies and procedures for identifying and reporting suspicious activities.
• The legal and regulatory obligations of the Company and employees.
• The consequences of non-compliance.

The Company will maintain comprehensive records of all customer identification documents, transactions, and reports of suspicious activities for a minimum of [X] years, in accordance with local laws and regulatory requirements. These records will be available for inspection by regulatory authorities.

The Company will ensure that it does not provide services to individuals or entities subject to international sanctions or based in high-risk jurisdictions. The Company will maintain an up-to-date list of sanctioned individuals, entities, and countries and conduct screening against relevant sanctions lists.

The Company will conduct regular reviews of its AML policies and procedures to ensure they remain effective and compliant with changing laws and regulations. The Company will also conduct regular internal audits and reviews of customer accounts, transaction data, and AML processes.

Any employee or third-party partner found to be in violation of the Company's AML policies will face disciplinary action, which may include termination of employment or termination of the business relationship. Criminal or civil prosecution may also be pursued if warranted.