Anti-Money Laundering

1. Introduction

Money laundering is the process by which the proceeds of crime are transformed into ostensibly legitimate money or other assets. Paytia Limited (“Paytia”) is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires management and employees to adhere to these standards to prevent use of our services for money laundering purposes.

2. Policy Statement

Paytia is committed to complying with all applicable anti-money laundering laws and regulations in the countries in which it operates, including the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. We will not knowingly engage in transactions with or provide services to individuals or organisations who engage in money laundering, terrorist financing, or other financial crimes.

3. Scope

This policy applies to all Paytia operations, employees, contractors, and third parties acting on behalf of Paytia, regardless of their location. All business units and functions within Paytia must comply with this policy.

4. Risk Assessment

Paytia will conduct periodic risk assessments to identify and assess money laundering and terrorist financing risks that may arise in relation to:

• The development of new products, services, and business practices
• The use of new or developing technologies
• Customer relationships and transactions
• Geographic areas of operation

5. Know Your Customer (KYC)

Paytia follows robust Know Your Customer procedures to:

• Verify the identity of clients
• Establish the nature of their business activities
• Assess money laundering risks associated with that client
• Monitor client transactions for suspicious activity

Depending on the risk assessment, enhanced due diligence may be required for certain customers, products, services, or geographic locations.

6. Transaction Monitoring

Paytia monitors customer transactions for suspicious activities that may indicate money laundering or terrorist financing, including:

• Transactions involving high-risk countries or geographic locations
• Complex or unusual large transactions
• Unusual patterns of transactions with no apparent economic or lawful purpose
• Transactions that raise suspicion of terrorist financing

7. Suspicious Activity Reporting

Employees must report suspicious activities to the Money Laundering Reporting Officer (MLRO). The MLRO will investigate the reported activity and determine whether a Suspicious Activity Report (SAR) should be filed with the appropriate authorities, including the National Crime Agency.

8. Record Keeping

Paytia will maintain all records related to AML compliance, including:

• Customer identification and verification documents
• Transaction records
• Risk assessments
• Reports of suspicious activity
• AML training records

These records will be maintained for at least five years, or as required by applicable regulations.

9. Training

Paytia will provide regular anti-money laundering training to all relevant employees to ensure they understand:

• Their legal responsibilities
• Regulatory requirements
• Internal policies and procedures
• How to identify and report suspicious activity

10. Compliance Monitoring and Review

Paytia's compliance function will monitor the effectiveness of AML controls and review the AML policy regularly to ensure it remains current with applicable regulations and best practices. Any deficiencies will be reported to senior management and addressed promptly.

This policy has been approved by the company's Board of Directors, who will review and update it annually.

If you have questions about our Anti-Money Laundering Policy or would like to report concerns, please contact compliance@paytia.com.