SayPay anti-money laundering and terrorism financing policy (AML/TF)

This policy defines the principles, roles and procedures implemented by SayPay to prevent and combat money laundering and terrorism financing (AML/TF), in compliance with applicable laws and regulations in operating countries, as well as international standards. It aims to ensure that SayPay is not used as a vector for illicit activities, to protect the integrity of the financial system and to contribute to the trust of users and partners.

This policy applies to: - All internal and external SayPay collaborators. - All services and products provided by SayPay. - All users, clients or partners of SayPay. It covers all countries where SayPay operates, taking into account local specificities.

SayPay commits to respect: - National laws on AML/TF. - FATF (Financial Action Task Force) recommendations. - Directives from COBAC, BEAC, CENTIF, ANIF, or any other local regulator. - International conventions (UN, OECD, EU, etc.).

Due diligence principle: identification and knowledge of clients before any relationship. Continuous monitoring principle: tracking of operations and client behavior. Reporting principle: mandatory transmission of suspicious operations. Training principle: regular awareness of staff. Proportionality principle: application of measures according to risk level.

Initial identification Every user must: - Provide an active phone number. - Go through a verification process via valid identity document (OCR). - Submit to facial verification (liveness detection). Additional information Additional documents may be required: - Proof of address. - Proof of income or professional activity. - Information on the origin of funds. High-risk clients - PEP (politically exposed persons). - Residents of high-risk countries (FATF list). - Sensitive activities (cryptocurrencies, gaming, etc.). Enhanced due diligence applies to these profiles.

Monitoring tools SayPay uses automated systems to: - Detect unusual behaviors. - Generate alerts on atypical amounts or frequencies. - Temporarily block suspicious operations. Risk indicators Examples of warning signals: - Multiple split transactions. - Use of third-party accounts. - Transfers to risk zones without justification. - Creation of multiple accounts with similar identities. Analysis and investigation Reported operations are analyzed by the compliance team. Documentation is compiled for each case.

Internal procedure - Staff or system escalates the alert to the Compliance Officer. - He/she conducts an in-depth analysis. - If the suspicion is founded, a report is established. Transmission to authority - Depending on the country concerned, the report is transmitted to the reporting body (e.g., ANIF, CENTIF). - This transmission is confidential and protected by professional secrecy. Non-disclosure prohibition It is strictly forbidden to inform the client that a report is in progress (non-disclosure obligation).

SayPay organizes mandatory training for: - All new collaborators. - Exposed profiles (customer support, operations). - Technical staff involved in security or KYC systems. An annual update is performed.

Compliance Officer (AML Officer) - Manages the application of this policy. - Processes alerts. - Maintains an incident log. - Updates the AML/TF policy. Management - Provides necessary human and technical resources. - Validates procedures. - Ensures strategic follow-up.

- Identification documents: kept for 10 years after the end of the client relationship. - Transactions: logged for 5 years. - AML/TF reports and documents: securely archived for at least 5 years.

Any provider or partner must: - Comply with an equivalent AML policy. - Sign a compliance agreement. - Allow SayPay audits on AML/TF procedures.

- Suspend or close a user account. - Initiate internal proceedings against a collaborator. - Terminate a contractual relationship with a partner.

- Every 12 months. - In case of regulatory modification or new identified risk. It is approved by the General Management and disseminated to all levels of the company.

For any questions regarding compliance or to report an incident: Email: hello@saypay.ai