In accordance with the security standards for our users and the legal obligations of Canada, the European Union, the United States, and other applicable jurisdictions, PAYER PAY INTERNATIONAL INC. has developed and implemented KYC (Know Your Customer) and AML/CTF (Anti-Money Laundering and Counter-Terrorist Financing) procedures in compliance with the requirements of FINTRAC (Financial Transactions and Reports Analysis Centre of Canada). The purpose of these policies is to effectively prevent money laundering and terrorist financing (AML/CTF). By verifying user identities and closely monitoring transactions, we aim to detect and prevent activities primarily intended to conceal the origin of illicit funds, finance illegal activities, or engage in unlawful conduct through the purchase or sale of cryptocurrency. Certain sections of our policies remain confidential and are for internal use only, in order to prevent abuse by fraudsters. However, we will outline some general guidelines relevant to users and affecting the services we provide. User Identification We are required to verify with a high degree of confidence the identities of individuals conducting transactions on our platform. To do this, we collect scans of identity documents, which are authenticated using specialized software provided by third-party vendors. We may also request a selfie or a video featuring your ID document to prevent unauthorized use. Matching your appearance to the photo in your ID is carried out using advanced software from third-party providers, or, in ambiguous cases, manually by our customer support team. If any issues arise, our customer support team will contact you to resolve them. In situations where we cannot confidently verify the authenticity of your documents, we will be unable to process your transactions.
KYC Questionnaire Why do we collect personal data? Clients expect their financial institutions to provide safe and high-quality services. To meet these expectations, financial institutions worldwide follow the “Know Your Customer” standard, and we are no exception. In adherence to this standard, we periodically request information about clients’ financial activities and regularly update personal data in our system. This process applies universally to all clients and is not an indication of any suspicion. By collecting this information, we help protect against financial fraud and identity theft, safeguarding your assets and interests. After registration, you may receive a KYC questionnaire at the email address you provided. Please answer the questions carefully and send the completed form to [email protected]. Each form is filled out individually, and the responses will vary depending on your occupation, income, and other factors. Guidelines for Completing the KYC Form 1. Source of Funds Please select the source(s) of your funds. Multiple options may apply. For example, if your income consists of both a salary and self-employment earnings, select both. If you choose options such as “self-employment” or “other,” please provide detailed information about those sources. 2. Estimated Monthly Turnover Indicate your estimated monthly turnover. For instance, if your monthly income is approximately €800 with no other sources, select “up to €1,000.” 3. Political Activity Specify whether you currently hold, or have held in the past year, any political position, such as a role in parliament or a political party. Select “yes” if you have been politically active within the last 12 months. 4. Close Associates Indicate whether any of your close associates have held significant political positions during the past 12 months. 5. Ultimate Beneficial Owner (UBO) The account holder must be the ultimate beneficial owner and the legal owner of the funds in the account. Please note that accounts can only be opened for personal use. Frequency of Data Requests We may request your information: • During the registration process; • Annually, for data updates; • In cases of unusual or high-value transactions. Additional questions may be asked regarding the purpose of the transaction, the source of funds, etc. Consequences of Failing to Provide Information If the required information is not provided in a timely manner, access to certain financial services may be restricted. Accurate and timely responses help us process your transactions, lift restrictions, and provide full access to PAYER PAY services. Data Security and Access Your data is securely stored and used exclusively for security and compliance purposes. However, we cooperate with law enforcement authorities, who may request information about clients' financial activity from payment service providers. Data Collection We may request various types of information, such as contact details or information related to specific transactions. This data is not used for marketing or any other non- compliance-related purposes. Regulatory Compliance All data collection is conducted in accordance with legislation governing financial institutions and is intended to support anti-money laundering (AML) and counter- terrorist financing (CTF) efforts. Corporate Client Identification For legal entities, the AML/KYC process is more rigorous and takes into account the company’s structure, jurisdiction, and nature of business. This includes identifying ultimate beneficial owners (UBOs), verifying shareholders, partners, and holding structures (if applicable), as well as reviewing corporate documentation to ensure regulatory compliance. Given the differences between jurisdictions, corporate entities are often reviewed manually for compliance with the legal requirements of specific countries. Required documents may include: • Certificate of incorporation; • Founding documents (Articles of Association or Partnership Agreement); • Identity documents of directors and authorized representatives; • Shareholder agreements or partnership contracts; • Proof of registered business address; • Financial statements or bank references. Enhanced Due Diligence (EDD) may be applied in cases involving high-risk jurisdictions, high-risk industries, or flagged types of business activity. Transaction Monitoring and Review We use proprietary software to monitor all transactions on our platform for suspicious or unusual activity. Flagged transactions are reviewed by our AML/CTF compliance specialists, who assess the associated risk. Additional Verification As trading volume increases, AML/CTF requirements may become more stringent. This may include requests for additional documents, such as proof of residential address or detailed information about the source of funds. If our AML/CTF specialists determine that the information provided is insufficient, we may be required to terminate the business relationship and report the transaction to the relevant authorities. Basic AML/CTF Rules Our rules include: - Identifying each client under the KYC standard; - No acceptance of cash deposits or withdrawals; - No exceptions to required documentation; - The right to halt transactions if AML/CTF risks are suspected; - Non-disclosure of reports to authorities regarding suspicious activity. Sanctioned Countries In compliance with our internal policies and Canadian legislation, PAYER PAY INTERNATIONAL INC. does not engage in trade or process transactions for individuals residing in or visiting jurisdictions subject to international sanctions, as well as regions identified as high-risk for Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. Transactions are restricted in regions based on various established criteria, which include, but are not limited to: International Sanctions: Canada follows the United Nations Act, the Special Economic Measures Act (SEMA), and other legal frameworks to enforce sanctions. These sanctions may restrict or prohibit financial transactions involving countries or entities involved in human rights violations, terrorism, or security threats. We adhere to these regulations and ensure that transactions originating from or destined for sanctioned countries are not processed. AML/CTF Risk Assessments: In addition to sanctioned nations, we restrict activities in jurisdictions designated as high-risk by various authorities: Transparency International’s Corruption Perceptions Index: High levels of corruption correlate with money laundering risks. Countries with consistently poor ratings are therefore flagged. Financial Action Task Force (FATF) Warnings: FATF issues advisories on jurisdictions with weak anti-money laundering and counter-terrorism financing measures. These "high-risk" or "non-cooperative" jurisdictions are subject to heightened scrutiny and limitations. European Commission AML Blacklists: The European Commission regularly evaluates and updates a list of non-cooperative jurisdictions with deficient AML and CTF frameworks, which we also consider in our compliance. Additional High-Risk Indicators: Based on PAYER PAY INTERNATIONAL INC. internal AML team assessments, countries may be restricted due to specific factors such as political instability, lack of regulatory oversight, and involvement in financing terrorism or organized crime. Other indicators include geographic proximity to conflict zones or ongoing regional conflicts. By following these guidelines, PAYER PAY INTERNATIONAL INC. ensures that we operate within the requirements of Canadian law and international standards, while minimizing exposure to AML/CTF risks. Our policies and sanctions list are reviewed regularly and updated to reflect new regulatory requirements and international developments. Currently, these countries are: Afghanistan, American Samoa, Angola, Bahamas, Botswana, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, USA (some states), Russian Federation, Belarus.
KYC Verification Levels Clients on https://payerpay.io/ must complete KYC-AML verification through our AML provider, https://sumsub.com, accessible via a link in their account. With increasing trade volume, AML/CTF risks also rise, requiring a three-tier verification model that adjusts with regulatory changes and audit findings. Any changes to procedures will be communicated promptly. June 20, 2025