AML COMPLIANCE POLICY

1. Introduction

CPayant, a brand of DB Technology Innovations Ltd., is firmly committed to complying with all applicable global Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations. This policy outlines the comprehensive principles and procedures we diligently implement to mitigate the risk of our services being misused for illegal activities.

2. Risk Assessment

CPayant fully acknowledges that the inherent nature of the financial services industry makes it susceptible to money laundering and terrorist financing activities. We conduct thorough and regular risk assessments to meticulously identify and understand the specific money laundering and terrorist financing risks associated with our unique business model, valued customer base, and geographical location. These assessments are instrumental in tailoring our robust AML/CTF compliance program accordingly.

3. Customer Due Diligence (CDD)

CPayant implements a robust customer due diligence (CDD) program to meticulously verify the identity of our customers and meticulously assess the money laundering and terrorist financing risks associated with them. This comprehensive program encompasses:

• Customer Identification and Verification: We adhere to stringent global regulations by collecting and verifying the identities of our customers using reliable and independent sources of documentation.
• Know Your Customer (KYC): We gather in-depth information about our customers' business activities, sources of funds, and anticipated transaction patterns to gain a comprehensive understanding of their financial profile and risk level.
• Enhanced Due Diligence (EDD): We apply rigorous enhanced due diligence measures for higher-risk customers, such as those located in high-risk jurisdictions, politically exposed persons (PEPs), and customers involved in high-value or complex transactions.

4. Transaction Monitoring

CPayant diligently monitors all customer transactions for any suspicious activity that might indicate money laundering or terrorist financing. Our state-of-the-art transaction monitoring system is meticulously designed to detect and flag transactions that deviate from a customer's profile, exceed established thresholds, or involve high-risk countries or entities.

5. Reporting

CPayant is legally obligated to report any suspected cases of money laundering or terrorist financing to relevant jurisdictional authorities, as mandated by law. We also meticulously comply with all reporting obligations related to unusual transactions or customer activity.

6. Training and Awareness

CPayant is committed to providing ongoing training to all employees on AML/CTF regulations and our comprehensive internal compliance procedures. We ensure that our employees are fully aware of their individual responsibilities in preventing money laundering and terrorist financing and are equipped to effectively identify and report any suspicious activity.

7. Management Oversight

CPayant's dedicated management team is firmly committed to ensuring the unwavering effectiveness of our AML/CTF compliance program. We conduct regular reviews and updates of our policies and procedures to ensure alignment with evolving regulations and best practices. We also conduct rigorous internal audits to meticulously assess the effectiveness of our program and identify areas for continuous improvement.

8. Continuous Improvement

CPayant is dedicated to the continuous improvement of our AML/CTF compliance program. We conduct regular reviews of our risk assessments, update our policies and procedures as needed, and provide ongoing training to our employees to guarantee that we remain compliant with all applicable laws and regulations.

9. Additional Considerations

This AML compliance policy document serves as a comprehensive overview of our AML/CTF compliance program. It is not intended to be a substitute for professional legal advice. CPayant reserves the right to modify this policy at any time without prior notice.

10. Contact Information

For any inquiries regarding this AML compliance policy, please do not hesitate to contact our compliance officer at:

compliance@cpayant.com