AML/KYC Policy

1. Introduction

This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") describes the compliance measures implemented by Fast Payment System ("FPS", "Company", "we", "us", or "our") to prevent money laundering, terrorist financing, sanctions violations, fraud, and other unlawful activities.

FPS is committed to maintaining a risk-based compliance framework and may take all actions reasonably necessary to comply with applicable laws, regulations, sanctions requirements, and industry standards.

2. Scope

This AML/KYC Policy applies to:

• Users;
• Merchants;
• Beneficial owners;
• Authorized representatives;
• Business entities;
• Any other persons utilizing FPS services.

3. Risk-Based Approach

FPS applies a risk-based approach when assessing customers, merchants, transactions, and jurisdictions.

Factors considered may include:

• Country of residence or incorporation;
• Nature of business activities;
• Transaction volume and frequency;
• Source of funds;
• Source of wealth;
• Blockchain risk indicators;
• Sanctions exposure;
• Adverse media findings;
• Fraud indicators.

4. Customer Due Diligence (CDD)

FPS reserves the right to identify and verify any customer before or during the provision of services.

Verification procedures may include:

FPS may request documentation at any time.

• Identity verification;
• Proof of address;
• Business verification;
• Beneficial ownership verification;
• Source of funds verification;
• Source of wealth verification;
• Additional compliance checks.

5. Enhanced Due Diligence (EDD)

FPS may conduct Enhanced Due Diligence for:

Additional information and documentation may be required before services are provided or continued.

• High-risk customers;
• High-risk merchants;
• High-risk jurisdictions;
• Unusual transactions;
• Large transaction volumes;
• Customers presenting elevated compliance risks.

6. Merchant Verification

FPS reserves the right to verify merchants and their business activities.

Merchants may be required to provide:

• Company registration documents;
• Ownership information;
• Business descriptions;
• Website information;
• Proof of operational activity;
• Additional documentation deemed necessary.

7. Transaction Monitoring

FPS continuously monitors transactions and customer activity.

Monitoring procedures may include:

• Transaction pattern analysis;
• Behavioral analysis;
• Blockchain transaction review;
• Risk scoring;
• Sanctions screening;
• Fraud detection.

8. Blockchain Analytics

FPS may utilize blockchain analytics providers and risk assessment tools to identify:

• Sanctioned addresses;
• Darknet-related activity;
• Stolen assets;
• Fraud indicators;
• High-risk wallets;
• Other suspicious blockchain activity.

9. Source of Funds and Source of Wealth

FPS may request information regarding:

Failure to provide requested information may result in suspension or termination of services.

• Source of funds;
• Source of wealth;
• Business activity;
• Transaction purpose;
• Supporting financial documentation.

10. Sanctions Compliance

FPS prohibits the use of its services by individuals, entities, organizations, or beneficial owners subject to sanctions imposed by:

FPS reserves the right to block, suspend, restrict, or terminate services where sanctions concerns are identified.

• OFAC;
• European Union;
• United Kingdom;
• United Nations;
• Any other competent sanctions authority.

11. Restricted Jurisdictions

FPS does not open accounts, provide services, process transactions, or establish business relationships with individuals, legal entities, merchants, beneficial owners, or other related parties who are located in, resident in, citizens of, incorporated in, operating from, or otherwise connected to the following jurisdictions:

• Islamic Republic of Afghanistan (AF)
• Republic of Angola (AO)
• Republic of Belarus (BY)
• Bosnia and Herzegovina (BA)
• Republic of Botswana (BW)
• Commonwealth of The Bahamas (BS)
• Kingdom of Cambodia (KH)
• Republic of Burundi (BI)
• Democratic Republic of the Congo (CD)
• Central African Republic (CF)
• Republic of the Congo (CG)
• People's Democratic Republic of Algeria (DZ)
• Republic of Ecuador (EC)
• State of Eritrea (ER)
• Federal Democratic Republic of Ethiopia (ET)
• Republic of Ghana (GH)
• Republic of Guinea (GN)
• Republic of Guinea-Bissau (GW)
• Co-operative Republic of Guyana (GY)
• Republic of Haiti (HT)
• Republic of Iraq (IQ)
• Islamic Republic of Iran (IR)
• Japan (JP)
• Republic of Kenya (KE)
• Democratic People's Republic of Korea (KP)
• Lebanese Republic (LB)
• Republic of Liberia (LR)
• State of Libya (LY)
• Republic of the Union of Myanmar (MM)
• Federal Republic of Nigeria (NG)
• Islamic Republic of Pakistan (PK)
• Republic of Serbia (RS)
• Russian Federation (RU)
• Republic of the Sudan (SD)
• Democratic Socialist Republic of Sri Lanka (LK)
• Federal Republic of Somalia (SO)
• Republic of South Sudan (SS)
• Syrian Arab Republic (SY)
• Republic of Tunisia (TN)
• Republic of Trinidad and Tobago (TT)
• Ukraine (UA)
• Republic of Uganda (UG)
• United States of America (US)
• Republic of Vanuatu (VU)
• Bolivarian Republic of Venezuela (VE)
• Republic of Yemen (YE)
• Republic of Zimbabwe (ZW)

FPS reserves the right to modify the list of restricted jurisdictions at any time without prior notice.

12. Suspicious Activity

FPS reserves the right to investigate any activity deemed suspicious.

FPS may:

• Request additional information;
• Delay transactions;
• Restrict services;
• Suspend accounts;
• Terminate accounts;
• Report suspicious activity where required by law.

13. Refusal or Termination of Service

FPS may refuse service, suspend access, reject transactions, terminate accounts, or discontinue business relationships where:

• AML/KYC requirements are not satisfied;
• Compliance concerns arise;
• Fraud is suspected;
• False information is provided;
• Legal or regulatory risks exist.

14. Record Retention

FPS may retain customer information, verification records, transaction records, and compliance documentation for as long as required by law, regulatory obligations, internal policies, and legitimate business purposes.

15. Amendments

FPS reserves the right to amend this AML/KYC Policy at any time.

The latest version will be published on the FPS website.

16. Contact Information