Anti-Money Laundering (AML) Policy

1. INTRODUCTION AND COMMITMENT

ZyndPay (referred to as "ZyndPay", "we", "us", or "our") is a technology platform that provides cryptocurrency payment processing services. This Anti-Money Laundering and Counter-Terrorism Financing Policy (the "AML Policy" or "Policy") sets forth the principles, procedures, and controls that ZyndPay voluntarily implements to prevent the misuse of its services for money laundering, terrorist financing, proliferation financing, fraud, or any other financial crime.

ZyndPay is committed to operating responsibly and maintaining the integrity of the global financial system. As part of this commitment, ZyndPay voluntarily adopts robust Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) measures aligned with the Financial Action Task Force (FATF) Recommendations, including updated guidance on Virtual Assets and Virtual Asset Service Providers (VASPs), as well as other widely recognized international best practices. These measures are implemented as part of our dedication to responsible business conduct, transparency, and the prevention of financial crime — not as a result of any specific regulatory mandate, but because we believe it is the right way to operate a cryptocurrency payment platform.

2. SCOPE AND APPLICATION

This Policy applies to: (a) all merchants ("Merchants") registered on the ZyndPay platform; (b) all transactions processed through the Services, including payins, payouts, and withdrawals; (c) all team members and contractors of ZyndPay who are involved in compliance, operations, or management of the Services; and (d) all third-party service providers engaged by ZyndPay in connection with AML compliance. This Policy is reviewed and updated regularly, or more frequently as warranted by changes in international standards, industry developments, or emerging risks.

In addition to its merchant-facing KYB program, ZyndPay also operates a consumer custodial wallet and a peer-to-peer (P2P) marketplace. Individual holders of the ZyndPay consumer wallet are subject to a risk-based Know Your Customer (KYC) tiering program, under which the level of identity verification and transaction limits applied to each user is proportionate to the assessed risk of that user's activity. The AML/CTF monitoring, screening, and reporting obligations described in this Policy apply equally to consumer wallet holders and P2P marketplace participants, not solely to Merchants.

3. RISK-BASED APPROACH

ZyndPay adopts a risk-based approach to AML/CTF, whereby the level of due diligence and monitoring applied to each Merchant and transaction is proportionate to the assessed level of risk. Risk assessments consider the following factors:

3.1 Merchant Risk Factors: (a) jurisdiction of operation; (b) nature of business activities; (c) expected transaction volumes and patterns; (d) beneficial ownership structure; (e) source of funds; (f) previous screening results; and (g) any adverse media, sanctions, or politically exposed person (PEP) hits.

3.2 Transaction Risk Factors: (a) transaction amount and frequency; (b) source and destination wallet addresses; (c) wallet address risk scores from blockchain analytics providers; (d) patterns indicative of structuring or layering; (e) transactions involving high-risk jurisdictions; and (f) rapid movement of funds (deposits followed by immediate withdrawals).

3.3 Geographic Risk Factors: (a) countries identified by FATF as high-risk or under increased monitoring; (b) countries subject to comprehensive sanctions (UN, EU, US OFAC, UK HMT); and (c) countries with known deficiencies in AML/CTF frameworks.

3.4 Product/Service Risk Factors: (a) pseudonymous nature of cryptocurrency; (b) cross-border nature of blockchain transactions; (c) speed of transaction settlement; and (d) potential for peer-to-peer value transfer without intermediaries.

4. KNOW YOUR BUSINESS (KYB) — DUE DILIGENCE

4.1 Standard Due Diligence

All merchants must complete KYB verification and sign the master service agreement (MSA) before processing live transactions. Standard due diligence for full KYB includes: (a) verification of business identity through official registration documents; (b) identification and verification of beneficial owners holding 25% or more of the business; (c) identification of directors and authorized signatories; (d) verification of business address through independent documentation; (e) assessment of the nature and purpose of the business relationship; (f) screening against sanctions lists (UN, EU, US OFAC, UK HMT, and others); (g) PEP screening of beneficial owners and directors; (h) adverse media screening; and (i) source of funds assessment.

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied when: (a) the Merchant is assessed as high-risk based on our risk assessment methodology; (b) the Merchant operates in a high-risk jurisdiction; (c) beneficial owners or directors are identified as PEPs; (d) suspicious activity has been detected; or (e) the circumstances otherwise warrant additional scrutiny. EDD measures may include: additional identity verification steps, enhanced source of funds documentation, more frequent review cycles, senior management approval for the business relationship, and enhanced ongoing monitoring.

4.3 Ongoing Due Diligence

ZyndPay conducts ongoing due diligence throughout the business relationship, including: (a) periodic review of Merchant information and risk assessment (at least annually for standard-risk Merchants, semi-annually for high-risk Merchants); (b) continuous sanctions screening; (c) adverse media monitoring; (d) review of transaction patterns for consistency with the Merchant's risk profile; and (e) trigger-based reviews when suspicious activity is detected or significant changes occur in the Merchant's business.

5. TRANSACTION MONITORING

5.1 Automated Monitoring

ZyndPay employs automated transaction monitoring systems to detect potentially suspicious activity, including: (a) blockchain analytics tools for real-time transaction risk scoring; (b) wallet address screening against known illicit addresses, sanctioned addresses, and darknet-linked addresses; (c) pattern detection for structuring (breaking down large transactions into smaller ones to evade thresholds); (d) velocity checks for unusual transaction frequency; (e) monitoring for rapid fund movement (deposits immediately followed by withdrawals); (f) anomaly detection for transactions inconsistent with the Merchant's established patterns; and (g) threshold-based alerts for large or unusual transactions.

5.2 Manual Review

Transactions flagged by automated monitoring systems are escalated for manual review by qualified compliance personnel. Manual review includes: (a) analysis of the transaction context and Merchant history; (b) review of blockchain analytics data; (c) contact with the Merchant to request explanation or additional documentation, where appropriate; and (d) determination of further action, including whether to allow, block, or hold the transaction.

5.3 Wallet Address Risk Assessment

ZyndPay assesses the risk of wallet addresses involved in transactions by: (a) querying blockchain analytics providers for wallet address risk scores; (b) checking for direct or indirect connections to known illicit activity; (c) evaluating the wallet's transaction history and counterparty risk; and (d) blocking transactions from or to wallet addresses identified as high-risk, sanctioned, or associated with illicit activity.

6. SUSPICIOUS ACTIVITY HANDLING

6.1 Internal Reporting

All team members and contractors of ZyndPay are required to report any suspicious activity or transactions to designated compliance personnel without delay. Reports may be triggered by: (a) unusual or unexplained transaction patterns; (b) transactions involving high-risk wallet addresses; (c) Merchant behavior inconsistent with their declared business activities; (d) attempts to structure transactions to avoid monitoring thresholds; (e) use of multiple accounts to circumvent controls; (f) reluctance to provide requested information or documentation; (g) transactions involving sanctioned countries, persons, or entities; and (h) any other activity that gives rise to a suspicion of money laundering or terrorist financing.

6.2 External Reporting

Where ZyndPay determines, in its sole judgment, that activity is suspicious or potentially illegal, ZyndPay may report such activity to relevant authorities as it deems appropriate. ZyndPay will cooperate with law enforcement and regulatory authorities as it considers necessary or appropriate in the circumstances. ZyndPay will: (a) not disclose to the Merchant or any third party that a report has been or will be made (no tipping off); (b) maintain complete records of all reports and investigations; and (c) respond to lawful requests for information from competent authorities.

7. SANCTIONS COMPLIANCE

ZyndPay maintains a comprehensive sanctions screening program, including: (a) real-time screening of all Merchants and their beneficial owners against major international sanctions lists, including United Nations Security Council Sanctions, European Union Sanctions, United States OFAC Sanctions (SDN List), and United Kingdom HM Treasury Sanctions; (b) screening of wallet addresses against sanctioned address lists; (c) blocking of transactions involving sanctioned countries, territories, persons, or entities; (d) regular updates to sanctions screening databases; (e) immediate account freezing and reporting when a sanctions match is confirmed; and (f) prohibition of circumvention, evasion, or facilitation of sanctions violations.

8. RECORD KEEPING

ZyndPay maintains comprehensive records, including: (a) KYB verification documentation, including copies of identification documents, business registration documents, and due diligence records — retained for a minimum of five (5) years after the termination of the business relationship; (b) transaction records, including amounts, dates, wallet addresses, and transaction hashes — retained for a minimum of seven (7) years; (c) investigation and reporting records — retained for a minimum of five (5) years; (d) internal reports and compliance decisions; (e) training records for all team members who receive AML training — retained for a minimum of five (5) years; and (f) risk assessments and policy review records. Records are stored securely and are available to competent authorities upon lawful request.

9. GOVERNANCE

9.1 Compliance Function

ZyndPay designates compliance personnel responsible for: (a) implementing and maintaining this Policy; (b) overseeing the AML program; (c) conducting risk assessments; (d) reviewing and escalating suspicious activity; (e) liaising with authorities as appropriate; (f) conducting AML training for team members; and (g) reporting to management on compliance matters.

9.2 Management

Management is responsible for: (a) ensuring that the AML program is adequately resourced; (b) approving this Policy and any material changes thereto; (c) reviewing the effectiveness of the AML program on a regular basis; and (d) fostering a culture of compliance throughout the organization.

10. TRAINING

ZyndPay provides AML training to all relevant team members upon onboarding and on a regular basis thereafter. Training covers: (a) AML best practices and international standards; (b) identification of suspicious activity and red flags; (c) internal reporting procedures; (d) sanctions compliance; (e) cryptocurrency-specific AML risks; and (f) consequences of non-compliance. Training records are maintained for a minimum of five (5) years.

11. ENFORCEMENT AND CONSEQUENCES

11.1 For Merchants: Violation of this Policy may result in: (a) immediate suspension or termination of the Merchant's Account; (b) freezing of the Merchant's balance; (c) blocking of pending transactions; (d) reporting to law enforcement or other relevant authorities; and (e) any other action deemed necessary by ZyndPay.

11.2 For Team Members: Failure to comply with this Policy may result in disciplinary action, up to and including termination of engagement.

12. POLICY REVIEW

This Policy is reviewed regularly by compliance personnel. Reviews consider: (a) emerging risks in the cryptocurrency industry; (b) developments in international AML standards and best practices; (c) changes in FATF recommendations or guidance; (d) results of internal audits and assessments; and (e) changes in ZyndPay's business model, products, or services.

13. CONTACT INFORMATION

For questions regarding this AML Policy or to report suspicious activity, please contact:

ZyndPay — Compliance
Email: [email protected]
General inquiries: [email protected]
Website: https://zyndpay.io