Anti-Money Laundering Website Policy

Last Updated: 28 November, 2023

Introduction

EukaPay US ("our," "we," the "Company," and "us"), is dedicated to preventing, detecting, and deterring individuals and entities involved in fraud, money laundering, and terrorist financing from utilizing EukaPay products and services. As a registered Money Service Provider (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and the Financial Crimes Enforcement Network (FINCEN) in the United States, we recognize the importance of preventing and combating money laundering activities and emphasize our commitment through this Anti-Money Laundering Policy (the “AML Policy”). EukaPay is also registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in Canada and operates as EukaPay Inc.

AML Compliance Program

EukaPay has established an AML Program designed to comply with AML laws and regulations in Canada, the U.S. and other applicable jurisdictions. This AML Policy underscores our ongoing commitment to identifying and preventing money laundering and terrorism financing in connection with our services. Acknowledging that combating money laundering is an ever-evolving process, we are vigilant in understanding and mitigating those potential risks. We continually evaluate the strength of our existing policies, procedures and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure they are well versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering and other financial crimes. Our AML Program includes:

• Designation of an AML Compliance Officer who is responsible for coordinating and monitoring the day-to-day compliance with the AML Program;

• AML risk assessments at the program, customer, and product and services levels;

• Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations

• Know Your Customer standards including a Customer Identification Program and Customer Due Diligence procedures reasonably designed to identify and verify all customers and, where applicable, beneficial owners, source of funds, and the nature and intended purpose of the business relationship, to the extent warranted by the risk of money laundering or terrorist financing or as required by regulation;

• Additional due diligence for higher-risk customers.

• Risk-based measures and systems for ongoing monitoring of transactions and activities through customers' accounts;

• Identification and reporting of suspicious transactions or activities to appropriate regulatory authorities in accordance with applicable laws;

• Procedures, processes and systems to produce other required reports and keep required records;

• Prohibition on conducting business with Shell Banks;

• Collect, store and share information on applicable virtual currency transfers in compliance with the travel rule requirements

• Independent audit and compliance testing to review and assess compliance with the AML Program and applicable laws;

• Training and education of appropriate employees and related third parties in applicable aspects of AML laws, rules and regulations, as well as the Company's processes and methodologies to mitigate the risk of money laundering;

• Maintaining appropriate registration and licensing, and

• Maintaining proactive measures to comply with changes to applicable AML regulations.

As a Crypto-Payments provider with US operations, we are also subject to the regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) and other sanctions regulators in the jurisdictions in which it operates. EukaPay has implemented policies and procedures reasonably designed to comply with the prohibitions and restrictions mandated by the sanctions laws and regulations applicable in the jurisdictions where the Company operates. EukaPay cooperates fully with investigations and inquiries from law enforcement and regulatory authorities pursuant to applicable laws and legal process.