Anti-Money Laundering & Counter-Terrorist Financing Policy

1. Policy Statement

The Coinepay group is headquartered in the United States, where its parent company World Card Ltd is based in New York. The Coinepay services are operated by the group company Green Banking Services Ltd. ("Green Banking", operating as Green Pay, Green Crypto Exchange and Green FX Exchange), a corporation incorporated in Ontario, Canada (World Card Ltd, Green Banking and their affiliates together, "Coinepay", "we", "us" or "our"). The United States and Canada are our principal places of operation.

We are committed to the highest standards of anti-money laundering ("AML"), counter-terrorist financing ("CTF") and sanctions compliance. We do not tolerate the use of our platform for money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion or any other financial crime.

This Policy summarises the controls that apply to every user of the Coinepay website, mobile application and related services (the "Services"). It forms part of the Coinepay User Agreement.

2. Legal and Regulatory Framework

Our AML/CTF compliance programme is designed to meet the requirements of the jurisdictions in which we operate:

• Canada (principal operating entity): the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, and ministerial directives issued under it. Green Banking Services Ltd. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB Registration No. N300000924) for foreign exchange dealing, money transferring, issuing and redeeming money orders, dealing in virtual currency, payment service provider activities and cheque cashing.
• United States (group headquarters): the Bank Secrecy Act (BSA) and its implementing regulations (31 C.F.R. Chapter X), the USA PATRIOT Act, and economic sanctions administered by the Office of Foreign Assets Control (OFAC). World Card Ltd (FinCEN MSB No. 31000329169972) and Coinepay Limited (FinCEN MSB No. 31000321315556) are registered with the Financial Crimes Enforcement Network (FinCEN) as Money Services Businesses.
• International standards: the Recommendations of the Financial Action Task Force (FATF) and United Nations Security Council sanctions resolutions.

Coinepay Pte. Ltd. (Singapore) and Coinepay Limited (Hong Kong) are liaison offices that carry out regional communication and partner coordination only. They do not conduct regulated financial services in Singapore or Hong Kong, and they comply with the local laws that apply to them.

Registration with FINTRAC or FinCEN does not constitute an endorsement or licence of our business by those agencies. Card issuance and fund custody are provided by licensed partner banks and financial institutions, which apply their own AML/CTF controls in addition to ours.

3. Governance

• A designated AML Compliance Officer is responsible for implementing the compliance programme and reports to senior management.
• Our written policies, procedures and risk assessment are kept up to date and approved by senior management.
• Employees and agents in relevant roles receive ongoing, written AML/CTF training.
• The effectiveness of the compliance programme is reviewed at least every two years, as required by Canadian law, and is subject to independent testing in accordance with U.S. requirements.

4. Risk-Based Approach

We assess the money laundering and terrorist financing risks associated with our customers, products, services and delivery channels, transaction types, geographic exposure and new technologies. The level of due diligence and monitoring applied to each customer is proportionate to the risk identified, and is reviewed throughout the business relationship.

5. Customer Due Diligence (KYC/KYB)

Before you can use the Services, and at any time afterwards, we will verify your identity using methods accepted under applicable law. Identity verification and screening are supported by our KYC partner Sumsub.

Individual customers

• Full legal name, date of birth, nationality, occupation and residential address;
• A valid, authentic government-issued photo identification document;
• Biometric liveness check and, where required, proof of address;
• Information on source of funds and the intended purpose and nature of the business relationship.

Business customers

• Certificate of incorporation, registration documents and proof of registered address;
• Identity of directors, authorised signatories and beneficial owners who directly or indirectly own or control 25% or more of the entity;
• Nature of business, ownership and control structure, expected transaction activity and source of funds.

We will not open or maintain anonymous accounts or accounts in obviously fictitious names. If you are unable or unwilling to provide the information we request, we may decline to provide, suspend or terminate the Services.

6. Enhanced Due Diligence

We apply enhanced measures where higher risk is identified, including for politically exposed persons ("PEPs") and heads of international organisations, their family members and close associates; customers connected to high-risk jurisdictions identified by the FATF or by ministerial directives; complex or unusual ownership structures; and unusually large or complex transactions. Enhanced measures may include additional documents on source of funds and source of wealth, senior management approval and more frequent reviews.

7. Sanctions Screening

All customers, beneficial owners and, where applicable, counterparties are screened at onboarding and on an ongoing basis against sanctions and watch lists, including Canadian sanctions under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act, entities listed under the Criminal Code of Canada, OFAC lists, United Nations Security Council lists, and lists maintained by the European Union and the United Kingdom. We do not provide Services to persons or entities subject to applicable sanctions, or to residents of jurisdictions subject to comprehensive sanctions.

8. Restricted Jurisdictions and Prohibited Activities

The Services may not be used, directly or indirectly, in connection with:

• Jurisdictions subject to comprehensive sanctions, jurisdictions subject to a ministerial directive restricting transactions, or jurisdictions identified by the FATF as high-risk jurisdictions subject to a call for action;
• Services related to virtual assets for residents of mainland China;
• Money laundering, terrorist or proliferation financing, or sanctions evasion;
• Fraud, scams, phishing, identity theft or the use of stolen payment credentials;
• Unlicensed gambling, unlicensed money transmission or unlicensed financial services;
• Illegal drugs, weapons, counterfeit goods, human trafficking, or any other unlawful goods or services;
• Pyramid or Ponzi schemes, or the provision of the Services to third parties without our consent ("nested" use).

We may update the list of restricted jurisdictions and prohibited activities at any time.

9. Ongoing Monitoring

We monitor accounts and transactions on an ongoing basis, using both automated systems and manual review, to identify activity that is unusual or inconsistent with a customer's profile. We may ask you at any time to explain a transaction or provide supporting documents, such as invoices, contracts or proof of source of funds. Information on the originator and beneficiary accompanies funds transfers and virtual currency transfers as required by law ("travel rule").

10. Regulatory Reporting

• Suspicious transactions: where there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, we report it to FINTRAC and, for U.S. activity, file Suspicious Activity Reports with FinCEN.
• Terrorist and listed property: we report property owned or controlled by or on behalf of a terrorist, terrorist group or listed person to FINTRAC and the relevant authorities, and freeze it as required.
• Prescribed reports: we file other reports required by law, including large cash transaction reports, large virtual currency transaction reports and international electronic funds transfer reports of CAD 10,000 or more.

By law, we may not inform you that a report has been made or is being considered.

11. Measures We May Take

To comply with our legal obligations, we may, without prior notice and to the extent permitted by law:

• Request additional information or documents;
• Delay, reject or reverse a transaction;
• Restrict, suspend or freeze an account or card;
• Terminate the business relationship;
• Cooperate with and disclose information to regulators and law enforcement agencies.

We will not be liable for any loss resulting from measures taken in good faith to comply with applicable laws.

12. Record Keeping

We retain customer identification records, transaction records, reports and related correspondence for at least five (5) years, as required by the PCMLTFA and the BSA, or for any longer period required by applicable law or requested by a competent authority.

13. Your Responsibilities

• Provide information that is true, accurate, complete and up to date, and notify us promptly of any change;
• Use the Services only for yourself or your own business, and only for lawful purposes;
• Not share your account, cards or credentials with any other person;
• Cooperate with our requests for information in a timely manner.

14. Contact

Questions about this Policy may be sent to our AML Compliance Officer:

• Green Banking Services Ltd., 114 Santa Monica Boulevard, Unit B-1, Scarborough, Ontario M1L 4H5, Canada
• Email: [email protected]