Anti-Money Laundering Policy

1. Introduction and Policy Statement

Everpay Corporation ("Everpay," "we," "us," or "our") is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires management, employees, and affiliates to adhere to these standards in preventing the use of our products and services for money laundering, terrorist financing, or other illegal activities.

This Anti-Money Laundering Policy (the "Policy") applies to all Everpay operations, employees, officers, directors, and third parties acting on behalf of Everpay. The purpose of this Policy is to establish a framework for compliance with all applicable AML laws and regulations, including but not limited to the Bank Secrecy Act (BSA), the USA PATRIOT Act, and other relevant federal and state regulations.

Everpay maintains a zero-tolerance policy towards money laundering and terrorist financing. We are committed to implementing and maintaining effective systems and controls to ensure full compliance with all applicable AML requirements.

2. Regulatory Framework

Everpay operates in compliance with the following key regulations and guidelines:

• Bank Secrecy Act (BSA): The primary U.S. anti-money laundering law, requiring financial institutions to assist government agencies in detecting and preventing money laundering.
• USA PATRIOT Act: Expands the scope of BSA requirements to combat terrorist financing and requires enhanced due diligence for certain accounts and customers.
• FinCEN Regulations: Financial Crimes Enforcement Network regulations governing suspicious activity reporting, currency transaction reporting, and customer due diligence.
• OFAC Sanctions: Office of Foreign Assets Control requirements prohibiting transactions with sanctioned individuals, entities, and countries.
• State Money Transmitter Laws: Applicable state-level regulations governing money transmission activities.
• FATF Recommendations: International standards set by the Financial Action Task Force for combating money laundering and terrorist financing.

3. AML Compliance Program

Everpay has established a comprehensive AML Compliance Program that includes the following key components:

3.1 Designation of a Compliance Officer

Everpay has designated a qualified individual as the AML Compliance Officer who is responsible for overseeing the AML Compliance Program, ensuring adherence to regulatory requirements, and serving as the primary point of contact for regulatory matters. The Compliance Officer reports directly to senior management and has the authority to implement and enforce all aspects of this Policy.

3.2 Written Policies and Procedures

Everpay maintains comprehensive written policies and procedures that are designed to ensure compliance with all applicable AML laws and regulations. These policies are reviewed and updated at least annually, or more frequently as required by changes in regulations or business operations.

3.3 Independent Testing

Everpay conducts independent testing of its AML Compliance Program on a regular basis, at least annually, to evaluate the effectiveness of the program and identify areas for improvement. Independent testing is conducted by qualified personnel who are not involved in the day-to-day operation of the compliance program.

3.4 Training Program

All Everpay employees receive AML training upon hiring and on an ongoing basis. Training covers the recognition and handling of suspicious transactions, customer identification procedures, regulatory requirements, and the consequences of non-compliance. Training is tailored to the specific roles and responsibilities of each employee.

4. Customer Due Diligence (CDD)

Everpay implements robust Customer Due Diligence procedures to verify the identity of our customers and assess the risks associated with their business relationships.

4.1 Customer Identification Program (CIP)

Before establishing a business relationship, Everpay collects and verifies the following information for all customers:

• For Individuals: Full legal name, date of birth, residential address, government-issued identification number (such as Social Security Number or passport number), and a valid government-issued photo identification document.
• For Business Entities: Legal name, principal place of business, tax identification number (EIN), formation documents, ownership structure, and identification of beneficial owners owning 25% or more of the entity.

4.2 Enhanced Due Diligence (EDD)

For customers that present a higher risk of money laundering or terrorist financing, Everpay applies Enhanced Due Diligence measures, which may include:

• Obtaining additional identification documentation
• Gathering information on the source of funds and source of wealth
• Conducting more detailed background checks
• Obtaining senior management approval for establishing or continuing the business relationship
• Implementing ongoing enhanced monitoring of the business relationship
• More frequent reviews of the customer relationship

4.3 Beneficial Ownership

In accordance with FinCEN's Customer Due Diligence Rule, Everpay identifies and verifies the identity of beneficial owners of legal entity customers. A beneficial owner is any individual who owns 25% or more of the equity interests of a legal entity customer, or who has significant responsibility to control, manage, or direct a legal entity customer.

5. Sanctions Screening

Everpay screens all customers, beneficial owners, and transactions against applicable sanctions lists, including:

• OFAC Specially Designated Nationals (SDN) List
• OFAC Consolidated Sanctions List
• FinCEN 311 Special Measures List
• Other applicable government and international sanctions lists

Screening is conducted at the time of customer onboarding and on an ongoing basis. Any potential matches are reviewed and escalated according to established procedures. Everpay prohibits transactions involving sanctioned individuals, entities, or countries.

6. Transaction Monitoring and Suspicious Activity Reporting

Everpay maintains robust transaction monitoring systems designed to detect suspicious activity, including:

• Unusual transaction patterns or volumes inconsistent with the customer's profile
• Transactions with no apparent business or lawful purpose
• Transactions involving high-risk jurisdictions
• Structuring of transactions to avoid reporting thresholds
• Rapid movement of funds without apparent business reason
• Transactions inconsistent with the customer's stated business purpose

6.1 Suspicious Activity Reports (SARs)

When Everpay identifies suspicious activity, we file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of the initial detection of facts that may constitute a basis for filing a SAR. Everpay maintains records of all SARs filed and any supporting documentation for a period of five years.

Everpay employees are prohibited from disclosing to any person involved in the transaction that a SAR has been filed (the "SAR confidentiality rule"). Violation of this rule may result in civil and criminal penalties.

7. Record Keeping

Everpay maintains comprehensive records in accordance with applicable regulatory requirements, including:

• Customer identification records for at least five years after the account is closed
• Transaction records for at least five years from the date of the transaction
• Suspicious Activity Reports and supporting documentation for at least five years from the date of filing
• AML training records for at least five years
• Independent testing reports and supporting documentation

8. Prohibited Activities

Everpay prohibits the use of its services for any of the following activities:

• Money laundering or terrorist financing
• Fraud, including identity theft and payment fraud
• Transactions involving illegal goods or services
• Transactions involving sanctioned individuals, entities, or countries
• Structuring transactions to evade reporting requirements
• Any activity that violates applicable laws or regulations
• Transactions involving Politically Exposed Persons (PEPs) without appropriate enhanced due diligence

9. Risk Assessment

Everpay conducts periodic risk assessments to identify and assess money laundering and terrorist financing risks associated with our products, services, customers, and geographic locations. Risk assessments inform the development and implementation of appropriate controls and are updated at least annually or when significant changes occur in our business operations or regulatory environment.

Our risk assessment methodology considers the following factors:

• Types of products and services offered
• Customer types and risk profiles
• Geographic locations of customers and transactions
• Transaction volumes and values
• Delivery channels used
• Third-party relationships

10. Third-Party Relationships

Everpay conducts due diligence on third parties who perform services on our behalf that relate to our AML obligations. We ensure that third parties maintain appropriate AML programs and comply with applicable regulations. Third-party relationships are subject to ongoing monitoring and periodic review.

11. Cooperation with Law Enforcement

Everpay cooperates fully with law enforcement agencies and regulatory authorities in their efforts to combat money laundering and terrorist financing. We respond promptly to subpoenas, summonses, and other lawful requests for information. Everpay also participates in information-sharing programs as permitted by applicable law.

12. Whistleblower Protection

Everpay encourages employees to report suspected violations of this Policy or applicable AML laws and regulations. Employees who report violations in good faith are protected from retaliation. Reports may be made to the AML Compliance Officer, through our internal reporting channels, or directly to regulatory authorities.

13. Penalties for Non-Compliance

Violations of this Policy may result in disciplinary action, up to and including termination of employment. In addition, violations of AML laws and regulations may result in significant civil and criminal penalties, including fines and imprisonment. Everpay takes compliance seriously and expects all employees to adhere to this Policy and applicable laws.

14. Policy Review and Updates

This Policy is reviewed and updated at least annually, or more frequently as required by changes in regulations, business operations, or identified risks. Updates are communicated to all employees, and training is provided as necessary to ensure understanding of any changes.

15. Contact Information

If you have questions about this Policy or wish to report suspected money laundering or other illegal activity, please contact: