AML & CTF Policy

1. Purpose & scope

This Policy sets out the measures TsaraPay applies to detect and prevent money laundering ("ML"), terrorist financing ("TF"), and sanctions evasion, and to comply with applicable laws. It applies to all Merchants, personnel, and Transactions processed through the Services.

2. Legal & regulatory framework

We align our programme with applicable AML/CTF laws and international standards, including the recommendations of the Financial Action Task Force (FATF) and the AML/CTF regime(s) of [GOVERNING JURISDICTION(S)]. Where we or our partners are subject to specific licensing or regulatory requirements, we comply with those requirements.

3. Risk-based approach

We assess and manage ML/TF risk across customers, products, payment methods, geographies, and delivery channels. Higher-risk relationships are subject to stronger controls, closer monitoring, and senior approval. We keep our risk assessment under regular review.

4. Business & customer due diligence (KYB/KYC)

Before onboarding, and on an ongoing basis, we verify the identity of each Merchant, its beneficial owners, and controllers, and we assess the nature and purpose of the business relationship. This may include collecting incorporation documents, ownership structures, licences, identification of individuals, proof of address, and source-of-funds or source-of-wealth information. We will not establish or continue a relationship where we cannot complete satisfactory due diligence.

5. Enhanced due diligence (EDD)

We apply EDD to higher-risk situations, including politically exposed persons (PEPs), complex ownership structures, higher-risk jurisdictions, and unusual or high-value activity. EDD may include additional documentation, verification, and senior-management sign-off.

6. Sanctions & PEP screening

We screen Merchants, associated individuals, and, where appropriate, Transactions and counterparties against applicable sanctions lists (such as those of the UN, EU, UK, and US OFAC) and PEP and adverse-media data. We do not provide Services to sanctioned persons or to persons acting on their behalf, and we will block or reject Transactions where required.

7. Transaction monitoring

We monitor activity for patterns that may indicate ML, TF, fraud, or sanctions evasion, including unusual volumes, structuring, rapid movement of funds, and inconsistencies with a Merchant's expected profile. We may request explanations or supporting documentation, and may hold, delay, or reject Transactions pending review.

8. Reporting suspicious activity

Where we identify activity we know or suspect relates to ML, TF, or other financial crime, we will make the required reports to the competent authority or financial-intelligence unit. Applicable law may prohibit us from disclosing ("tipping off") that a report has been or may be made.

9. Record keeping

We retain due-diligence records, Transaction data, and compliance documentation for the period required by law (typically at least [FIVE (5)] years after the end of the relationship or the date of a Transaction), and make them available to authorities where required.

10. Prohibited & restricted activity

We do not knowingly facilitate: transactions involving sanctioned persons or jurisdictions; proceeds of crime; terrorist financing; unlicensed regulated activity; or any activity prohibited under our Terms of Service. Certain jurisdictions and business types may be restricted or subject to additional conditions.

11. Governance & training

Our compliance programme is overseen by a designated officer (Money Laundering Reporting Officer / [MLRO], [NAME/CONTACT]) with authority to escalate and report. Relevant personnel receive AML/CTF training appropriate to their role, and the programme is subject to periodic independent review.

12. Merchant responsibilities

Merchants must maintain their own AML/CTF controls appropriate to their business and jurisdiction, cooperate with our requests, promptly provide accurate information, and refrain from any activity that would cause TsaraPay or its partners to breach AML, CTF, or sanctions requirements. Failure to comply may result in suspension or termination and, where required, reporting to authorities.

13. Contact

Compliance enquiries: contact@tsarapay.com.

© 2026 TsaraPay. This Policy is a summary of our approach and does not disclose confidential controls. It may be updated as laws and risks evolve.