PAYBUDDIES.CO INTEGRATED TECHNOLOGY LTD

ANTI-MONEY LAUNDERING & COUNTER-TERRORIST FINANCING (AML/CFT) POLICY

1. POLICY STATEMENT

PAYBUDDIES.CO INTEGRATED TECHNOLOGY LTD (“the Company”), operating the PAYBUDDIES platform, is committed to preventing the use of its services for money laundering, terrorist financing, fraud, sanctions violations, and other financial crimes.

The Company implements a risk-based AML/CFT compliance framework aligned with applicable laws, regulatory guidance, and international standards for financial institutions and virtual asset service providers (VASPs).

The Company will not knowingly establish or maintain relationships with individuals or entities involved in criminal activity, sanctions violations, or terrorist financing.

2. SCOPE

This policy applies to:

• All employees, directors, and officers
• Contractors and third-party service providers
• Customers (individuals and businesses)
• Merchants and platform users
• All PAYBUDDIES products including: Crypto transfers; Fiat on/off-ramp services; Virtual card issuance

3. REGULATORY COMPLIANCE FRAMEWORK

The Company complies with applicable AML/CFT regulations including:

• Anti-Money Laundering (Prohibition) laws
• Terrorism Prevention legislation
• Nigerian Financial Intelligence Unit (NFIU) requirements
• FATF Recommendations
• Applicable international sanctions regimes (OFAC, UN, EU, UK HMT)

4. DEFINITIONS

• Money Laundering: Process of concealing or disguising proceeds of criminal activity.
• Terrorist Financing: Provision or collection of funds for terrorist purposes from lawful or unlawful sources.
• KYC/KYB: Customer and business identity verification procedures.
• PEP: Politically Exposed Person with heightened risk exposure.
• Beneficial Owner: Natural person who ultimately owns or controls an entity.
• Suspicious Transaction: Any activity inconsistent with a customer’s profile or indicative of financial crime.

5. AML/CFT GOVERNANCE STRUCTURE

5.1 Board & CEO

• Overall accountability for AML/CFT framework
• Approval of policies and risk appetite
• Resource allocation for compliance systems

5.2 Compliance Officer / MLRO

• Implementation of AML/CFT program
• Risk assessments and monitoring
• Suspicious activity investigations
• Regulatory reporting to authorities

5.3 Employees

• Mandatory compliance with AML/CFT controls
• Reporting suspicious activities
• Participation in compliance training

6. RISK-BASED APPROACH

The Company applies a multi-dimensional risk scoring model covering:

• Customer identity risk (KYC/KYB)
• Geographic risk
• Behavioral risk
• Transaction risk
• Counterparty exposure risk

Customers are classified as: Low Risk, Medium Risk, High Risk, Critical Risk.

Risk scores directly influence onboarding and transaction decisions.

7. CUSTOMER DUE DILIGENCE (KYC/KYB)

The Company performs identity verification before onboarding.

Individuals:

• Full name
• Date of birth
• Address
• Government-issued ID
• Contact details

Businesses:

• Registration documents
• Directors and shareholders
• Beneficial ownership structure
• Registered address verification
• Tax identification (where applicable)

8. ENHANCED DUE DILIGENCE (EDD)

Applied to:

• High-risk customers
• PEPs
• High-risk jurisdictions
• Complex or unusual transaction patterns

EDD includes:

• Source of funds verification
• Source of wealth verification
• Senior management approval
• Increased monitoring frequency

9. SANCTIONS & SCREENING PROGRAM

The Company screens all customers and transactions against:

• OFAC SDN List
• United Nations Sanctions List
• European Union Sanctions List
• UK HMT List
• PEP databases
• Adverse media sources

Screening occurs: At onboarding; Periodically; Before high-risk transactions.

10. COUNTER-TERRORIST FINANCING (CTF) CONTROLS

The Company maintains a zero-tolerance policy for terrorist financing. Controls include:

• Continuous sanctions and watchlist screening
• Monitoring for suspicious fund flows
• Blocking or escalating flagged transactions
• Investigation of high-risk activity
• Regulatory reporting to competent authorities

Indicators include:

• Structuring or smurfing transactions
• Transfers to high-risk jurisdictions
• Rapid movement of funds without justification
• Use of multiple accounts to obscure activity
• Sanctions exposure

11. TRANSACTION MONITORING SYSTEM

The Company operates a real-time monitoring system to detect:

• Velocity spikes in transactions
• Unusual transaction size deviations
• Circular fund flows
• Repeated failed transactions
• Abnormal behavioral patterns
• Crypto wallet risk exposure (where applicable)

All alerts are automatically escalated to compliance review.

12. RISK SCORING ENGINE

The Company uses a weighted risk model:

• KYC Risk: 35%
• Behavioral Risk: 25%
• Geographic Risk: 20%
• Counterparty Risk: 20%

Outputs:

• 0–30 → Allow
• 31–60 → Monitor
• 61–80 → Restrict / Review
• 81–100 → Block / Escalate

All decisions are logged and explainable.

13. SUSPICIOUS ACTIVITY REPORTING (SAR)

All suspicious activity must be reported immediately to the Compliance Officer. The Compliance Officer shall:

• Investigate the activity
• Document findings
• Escalate to authorities (including NFIU where applicable)
• Maintain audit records

Employees are strictly prohibited from tipping off customers.

14. RECORD KEEPING & AUDIT TRAIL

The Company maintains comprehensive records including:

• Customer identity documents
• Transaction history
• Risk scores and changes
• Compliance decisions
• Investigation reports

Records are retained for a minimum of 6 years or as required by law. All compliance actions are stored in an immutable audit trail system.

15. TRAINING & AWARENESS

All staff undergo mandatory AML/CFT training covering:

• Money laundering typologies
• Terrorist financing risks
• KYC/KYB procedures
• Sanctions compliance
• Reporting obligations

Training is conducted regularly and documented.

16. SYSTEMS & COMPLIANCE TECHNOLOGY

The Company may utilize third-party compliance tools for:

• Identity verification (KYC/KYB)
• Sanctions screening
• PEP checks
• Adverse media monitoring

The compliance system is designed to support:

• Real-time risk scoring
• Case management workflows
• Rule-based decision engines
• Audit and regulatory reporting

17. INDEPENDENT REVIEW

The AML/CFT program shall be reviewed periodically to ensure:

• Regulatory compliance
• Operational effectiveness
• Risk mitigation adequacy

Findings shall be reported to senior management.

18. BREACHES & SANCTIONS

Failure to comply with this policy may result in:

• Disciplinary action
• Account suspension
• Termination of relationship
• Regulatory penalties
• Criminal liability where applicable