AML Policy

1. General Framework

We have no tolerance for money laundering, the financing of terrorism, or any other form of illicit activity. We are committed to implementing appropriate policies, procedures, and controls to prevent such activities. Our policies are shaped by industry best practices, a risk-based approach, and effective anti-money laundering standards applied globally. These policies apply to all employees of the Company, its Board Members and Directors, as well as its subsidiaries, without exception.

The purpose of this document is to provide the Company’s Clients, Providers, Partners, Vendors, Contractors, Employees, Law Enforcement, and other stakeholders with a summarized overview of the Company’s main AML/CTF policies and procedures. This document does not encompass the entire set of policies, procedures, and controls implemented by the Company for the prevention of money laundering, terrorist financing, and other illicit activities.

Our policies and procedures are aligned with the provisions and recommendations of:

• The Money Laundering and Terrorist Financing Prevention Act, as amended.

• FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers.

As a regulated business, we comply with the requirements to:

• Identify and verify client identities.

• Conduct ongoing monitoring of client activities, including transaction monitoring.

• Maintain records of client activity and related documents for at least six years.

• Report suspicious transactions to the appropriate authorities.

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2. Risk-Based Approach

We adopt a risk-based approach (RBA) to assess and mitigate money laundering and terrorist financing risks. Our approach includes:

• Performing risk-based due diligence and collecting necessary information and documentation from prospective clients.

• Ensuring client identities do not match entities with criminal backgrounds or entities banned (e.g., terrorist organizations).

• Conducting enhanced due diligence (EDD) for high-risk clients, including those with unclear sources of funds or higher-value transactions.

Factors considered in risk assessment include:

• Client Risk: Nature and profile of the client.

• Geographical Risk: Jurisdiction and location of the client.

• Product Risk: Nature of products or services involved.

• Delivery Channel Risk: Means through which the service is delivered.

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3. Client Due Diligence (CDD)

We require all business clients to undergo proper due diligence or Know Your Business (KYB) checks before using our services. This includes:

• Verifiable company incorporation documents, including details on ownership, address, tax number, and activities.

• Description of the sector and corresponding online presence.

• Bank account details of the client.

For high-risk clients, additional documentation may include:

• Government-issued IDs of beneficial owners.

• Proof of address not older than three months.

• Video verification with authorized representatives or directors.

We use recognized electronic providers to verify client identity and may employ non-documentary methods such as:

• Public database verification.

• IP geolocation checks.

• Certified copies of identification documents.

Suspicious or incomplete information will trigger further investigation and potentially result in denial of service.

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4. Compliance Officer

A Compliance Officer oversees AML/CTF compliance. Their responsibilities include:

• Collecting and analyzing information on unusual or suspicious transactions.

• Reporting suspicious activities to relevant authorities.

• Regularly updating internal AML/CTF policies and procedures.

• Ensuring periodic compliance audits and employee training.

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5. Rules of Procedure & Internal Controls

The Company has implemented robust procedures for:

• Client due diligence (CDD) and enhanced due diligence (EDD).

• Identification and management of client and transactional risks.

• Data retention and reporting obligations.

• Monitoring transactions to identify unusual or suspicious patterns.

Employees are trained to follow these procedures and report any irregularities.

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6. Simplified Due Diligence (SDD)

Where risk assessments indicate lower risks, simplified due diligence measures may be applied. These measures allow:

• Reduced verification requirements.

• Monitoring of transactions to ensure compliance with AML/CTF standards.

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7. Enhanced Due Diligence (EDD)

Enhanced due diligence is mandatory for:

• Clients in high-risk sectors or jurisdictions.

• Clients whose transactional activity exceeds assigned risk thresholds.

• Suspicious or inconsistent client behavior.

EDD includes stricter documentation requirements and more frequent monitoring.

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8. Sector and Jurisdiction Restrictions

We do not serve clients from high-risk jurisdictions or restricted sectors. Clients providing false or forged documents to circumvent restrictions will be reported to authorities.

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9. Politically Exposed Persons (PEPs)

We apply enhanced scrutiny to PEPs, their families, and close associates. This includes additional risk assessments and monitoring to ensure compliance.

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10. Sanctions

We adhere to international sanctions, including those issued by:

• The European Union (EU).

• The United Nations (UN).

• The Office of Foreign Assets Control (OFAC).

Sanctioned entities are automatically flagged and blocked by our systems.

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11. Suspicious Activity Monitoring and Reporting

Suspicious activities are escalated to the Compliance Officer for investigation and reporting to relevant authorities. Employees are prohibited from informing clients about such reports.

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12. Termination of Services

We reserve the right to terminate services if a client is suspected of money laundering, terrorist financing, or other illicit activities.

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13. Data Retention

Client identification and verification records are retained for at least eight years after the termination of the business relationship. Data is processed solely for AML/CTF compliance.

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14. Training

The Compliance Officer ensures employees are trained on AML/CTF obligations, including trends and methods for preventing illicit activities.

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15. Cooperation and Information Requests

We cooperate with law enforcement and supervisory authorities in accordance with legal obligations. Information is disclosed only in response to enforceable requests, such as subpoenas or court orders.

Legal requests must include:

• Proof of authorization.

• Details of the information requested.

• A legitimate and enforceable subpoena or court order.

Requests should be sent to compliance@nfg-pay.com.