Anti-Money Laundering Policy

1. Policy Statement

PayzMoon LLC ("PayzMoon") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering ("AML") Policy outlines the measures, procedures, and controls we implement to detect and prevent the use of our payment processing services for illicit purposes.

PayzMoon complies with all applicable anti-money laundering laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and applicable guidance from the Financial Crimes Enforcement Network (FinCEN). We are also committed to complying with international AML standards as set forth by the Financial Action Task Force (FATF).

2. Know Your Customer (KYC) Requirements

PayzMoon implements robust KYC procedures for all merchants applying for payment processing services. Our KYC process includes:

2.1 Identity Verification

• Government-issued photo identification for all beneficial owners (passport, driver's license, or national ID)
• Proof of address dated within the last 3 months (utility bill, bank statement, or government correspondence)
• Business registration and incorporation documents
• Tax identification number verification
• Verification of authorized signatories

2.2 Business Verification

• Business license and permits verification
• Review of business website and operations
• Verification of physical business address
• Assessment of the nature and purpose of the business relationship
• Identification of ultimate beneficial owners (UBOs) holding 25% or more ownership

2.3 Enhanced Due Diligence (EDD)

Enhanced due diligence is conducted for higher-risk merchants, including:

• Merchants operating in jurisdictions with elevated money laundering risks
• Politically Exposed Persons (PEPs) and their associates
• Businesses with complex ownership structures
• Merchants with unusually high transaction volumes or values
• Any merchant flagged by our risk assessment systems

3. Transaction Monitoring

PayzMoon employs automated and manual transaction monitoring systems to detect suspicious activity. Our monitoring includes:

• Real-time Monitoring: Automated systems analyze transactions in real-time for patterns indicative of money laundering, fraud, or terrorist financing
• Threshold-based Alerts: Transactions exceeding defined thresholds trigger automatic review
• Pattern Analysis: Detection of unusual patterns such as structuring, layering, or rapid movement of funds
• Velocity Checks: Monitoring for unusual frequency or volume of transactions
• Geographic Risk Analysis: Identification of transactions involving high-risk jurisdictions
• Periodic Reviews: Regular review of merchant account activity to identify emerging risks

4. Suspicious Activity Reporting

PayzMoon is committed to reporting suspicious activity in accordance with applicable laws and regulations:

• Suspicious Activity Reports (SARs) are filed with FinCEN when suspicious activity is identified
• SARs are filed within 30 calendar days of initial detection of suspicious activity
• Currency Transaction Reports (CTRs) are filed for cash transactions exceeding $10,000
• All employees are trained to recognize and escalate potential suspicious activity
• Internal reporting procedures ensure timely escalation to our Compliance Officer

PayzMoon strictly prohibits "tipping off" any person about the filing of a SAR or the existence of a suspicious activity investigation. Violations of this prohibition may result in criminal penalties.

5. Sanctions Compliance

PayzMoon screens all merchants, beneficial owners, and transactions against applicable sanctions lists, including:

• U.S. Department of the Treasury OFAC Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated Financial Sanctions List
• UK HM Treasury Financial Sanctions List
• Other relevant national and international sanctions lists

Screening is performed at onboarding and on an ongoing basis. Any matches are investigated and reported as required. Transactions involving sanctioned parties are blocked.

6. Record Keeping

PayzMoon maintains comprehensive records in compliance with regulatory requirements:

• KYC documentation is retained for a minimum of 5 years after the termination of the business relationship
• Transaction records are retained for a minimum of 5 years from the date of the transaction
• SAR-related records are retained for 5 years from the date of filing
• Training records are maintained for the duration of employment plus 5 years
• All records are stored securely with appropriate access controls

7. Employee Training

PayzMoon provides comprehensive AML training to all employees:

• Initial AML training is provided to all new employees within 30 days of hire
• Annual refresher training is mandatory for all staff
• Specialized training is provided to compliance, risk, and customer-facing teams
• Training covers identification of suspicious activity, reporting obligations, and regulatory updates
• Training effectiveness is assessed through testing and evaluation

8. Compliance Governance

PayzMoon's AML compliance program is overseen by a designated Compliance Officer who is responsible for:

• Implementing and maintaining the AML compliance program
• Ensuring adherence to all applicable AML laws and regulations
• Conducting periodic risk assessments of our business operations
• Overseeing SAR filing and regulatory reporting
• Coordinating with law enforcement and regulatory agencies
• Reporting compliance matters to senior management and the board

Independent audits of our AML program are conducted annually to assess effectiveness and identify areas for improvement.

9. Merchant Responsibilities

Merchants using PayzMoon's services are expected to:

• Implement their own AML/KYC procedures appropriate to their business
• Not knowingly process transactions related to money laundering or terrorist financing
• Cooperate with PayzMoon's compliance requests and investigations
• Promptly report any suspicious activity to PayzMoon's compliance team
• Maintain accurate records of their customers and transactions
• Comply with all applicable AML laws in their jurisdiction

10. Enforcement and Consequences

Non-compliance with this AML Policy may result in:

• Immediate suspension or termination of merchant accounts
• Withholding or freezing of funds pending investigation
• Reporting to relevant law enforcement and regulatory authorities
• Legal action as deemed necessary

11. Contact Information

For questions about this AML Policy or to report suspicious activity, please contact: