1. Policy Summary
   AtPay Trading Pty Ltd (“@Pay”) is committed to comply with the high standards of
   anti-money laundering (“AML”) practice in all markets in which it operates, and to
   comply with both the specific provisions and the spirit of all relevant laws and
   regulations.
   @Pay focussed on conducting its business in accordance with all applicable laws
   and regulations, and in a way that enhances its reputation in the market.
   This policy applies not only to money laundering related to the proceeds of crime,
   but also to terrorist financing, and all references to money laundering.
   This policy records @Pay’s approach to the identification, mitigation and
   management of the risk that @Pay’s products and services might be involved in the
   facilitation of money laundering or the financing of terrorism.
   
   
2.  Statement on AML/CTF
   @Pay is required by law to comply with the Anti-Money Laundering and Counter- Terrorism Financing Act 2006 (“AML/CTF Act”), and the Anti-Money Laundering and Counter- Terrorism Financing Rules Instrument 2007 (“AML/CTF Rules”). The AML/CTF legislation is regulated by the Australian Transactions Reports and Analysis Centre (“AUSTRAC”) and has been introduced to align Australia with international standards on the prevention, detection and reporting of money laundering and terrorism financing. @Pay may also be required from time-to-time to comply with similar laws and regulations in other jurisdictions, for example in the United States of America, @Pay may be required to comply with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act 2001. @Pay’s AML/CTF compliance program (“Program”) is designed to meet the above requirements, which is overseen by a specially designated AML/CTF compliance officer.
   
   
3. Description of money laundering and terrorism financing
   @Pay defines money laundering (“ML”) as activity which is designed to conceal
   or disguise the true origin of criminally derived proceeds in order to make them
   appear to have been sourced from legitimate sources.
   Terrorist Financing (“TF”) is considered to be the act of providing financial
   support to terrorism or terrorist organisations to enable them to carry out
   acts of terrorism.
   
   
4.  Objectives
   @Pay has established an AML/CTF policy which sets the core principles for
   the management of ML/TF risk. The policy is global in nature and outlines company-wide standards to meet regulatory and ethical obligations in the economies in which @Pay does business. This contributes to the stability, integrity and strength of the global financial system and protects @Pay from reputational damage and regulatory action. The Policy is subject to regular review to ensure it remains current with regulator expectations and industry standards.
   
   
5. Core Principles
   @Pay has adopted the following core principles:
   
   – @Pay opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.
   – @Pay reports any activity that it detects which is suspicious and may involve potential money laundering or terrorism financing to the applicable regulator.
   – @Pay will comply with the AML/CTF laws, rules and regulations of the countries that relate to AML/CTF where @Pay has permanent places of business through which @Pay provides services.
   – @Pay will endeavor to provide its products and services only for legitimate purposes to customers whose identities @Pay has been able to reasonably ascertain.
   – @Pay will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by @Pay’s AML/CTF Program.
   – @Pay’s employees are required to attend AML/CTF training to understand their obligations under the relevant laws, rules and regulations.
   – @Pay will monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent.
   
   @Pay will manage new and revised changes to @Pay’s products, business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.
   
   
6. Customer Due Diligence
   Before doing business with any prospective customer, appropriate customer due diligence (CDD) is required to be undertaken and recorded. The CDD process comprises:
   (a) the identification and appropriate verification of identity of the customer (and, where different, beneficial owner) and any other relevant parties; and
   (b) additional and appropriate Know Your Customer (KYC) information, applying a risk-based approach.
       (1) A prospective customer’s identity should be obtained and verified using reliable, independent documentary and/or electronic source material. Without such, the prospective customer should be declined. Customer identification procedures for non-face to face business should include appropriate measures to mitigate the risks posed by such business.
       (2) Appropriate KYC information is required to be obtained prior to commencing the relationship and, applying a risk-based approach, updated on a regular basis during the course of the business relationship. KYC information includes, but is not limited to, appropriate personal, business, and financial details with regard to the customer, details on the purpose and intended nature of the business relationship, including anticipated transactional activity, details as to the source of funds.
   
   In no circumstances may accounts be operated or relationships established for anonymous customers or in obviously fictitious names.
   
   
7.  Know Your Customer (“KYC”)
   @Pay endeavours to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity and bona fides of customers will also be complied with. These will include:
   – Customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk to @Pay and require a higher level of due diligence;
   – Procedures to establish if customers are known or suspected money launderers, terrorists or otherwise engaged in criminal activity (e.g. reviewing customers against government/United Nations/regulators’ lists of proscribed persons);
   – Enhanced Due Diligence undertaken where a transaction or a counterparty results in a heightened level of financial crime or reputational risk;
   – A risk-based periodic review of existing customer records to maintain currency and completeness;
   – Ongoing monitoring of transactions conducted by customers using a risk based approach;
   – Procedures prohibiting accounts/relationships, including payment processing, with shell banks;
   – A clear statement on what records must be kept on customer identification and individual transactions and their retention period; and
   – Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.
   
   
8. Identification of Suspicious Transactions
   @Pay staff are trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with customers and customer related information.
   @Pay has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.
   It is a requirement that appropriate scrutiny and monitoring of transactions, account activity and customers are undertaken in order to identify unusual and potentially suspicious activity.
   Monitoring of transactions and account activity are undertaken applying a risk-based approach and having regard to the size and nature of the transaction. Transactions and account activity involving customers regarded as high risk are the subject of enhanced monitoring.
   
   
9. Reporting of Suspicious Transactions
   Every business unit in the Group is required to have procedures in place so that any transactions and/or activities which are believed to be suspicious are reported to a central Money Laundering Reporting Office function where the suspicions will be validated. If there are local legal or regulatory requirements for reporting suspicious transactions/activities, all validated cases are to be reported as required.
   
   
10. Maintaining Records
    Adequate records are required to be maintained to demonstrate that appropriate and ongoing CDD procedures have been followed, and to reconstruct transactions. These records are required to be maintained for at least 5 years after the relationship has ended or after the date of the transaction, or such longer period as required by local law or regulation.
    
    
11. Training
    All new relevant staff including temporary or contract staff who may be involved in customer business with suitable and timely induction training and refresher training to ensure that they understand @Pay’s approach to money laundering deterrence.
    Staff in high-risk areas are required to receive appropriate training to enable them to understand the money laundering techniques which are likely to be used in their area, and to remind them of their personal responsibilities.
12. Monitoring & Review of Money Laundering Deterrence
    Regular monitoring is required to be undertaken by line management and/or
    Compliance to check that all businesses are complying with the GPPs and with local legal and regulatory requirements.
    Operational and functional review work will be undertaken by Compliance and/or Audit functions, as appropriate. The level and frequency of monitoring and review work is required to be determined having regard to materiality and risk in relation to the business and customer base.
    
    
13. Independent Review of AML/CTF Program
    @Pay’s AML/CTF Program is subject to independent review in accordance with the requirements of each local jurisdiction. The results of the review are presented to senior management for review and action. In addition, regular reporting is provided by Compliance to @Pay’s Board.

Last updated: February 2023.