Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

Effective Date: February 9, 2026

Version: 1.0

1. Purpose

The purpose of this Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy is to establish effective controls to detect, prevent, and report money laundering, terrorist financing, and other illicit financial activities. PassCash is committed to complying with all applicable AML/CFT laws, regulations, and standards in the jurisdictions in which it operates, including the Caribbean and the United States.

2. Scope

This policy applies to all PassCash employees, officers, directors, contractors, agents, merchants, developers, and any other parties acting on behalf of PassCash. It also applies to all customers and all transactions conducted through the PassCash platform, including wallet services, currency exchange, escrow services, API integrations, merchant plugins, and agent operations.

3. Objectives

The objectives of this policy are to:

1. Ensure compliance with applicable AML/CFT laws and regulations.
2. Prevent PassCash from being used for money laundering or terrorist financing.
3. Identify, monitor, and report suspicious activities in a timely manner.
4. Apply a risk-based approach to customer due diligence and transaction monitoring.
5. Promote a strong culture of compliance and accountability within PassCash.

4. Key AML/CFT Measures

4.1 Customer Due Diligence (CDD)

PassCash verifies the identity of all customers before providing services.

Individuals

1. Full legal name
2. Date of birth
3. Residential address
4. Government-issued identification

Businesses and Merchants

1. Legal business name and registration details
2. Business address
3. Ownership and control structure
4. Authorized signatories

Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to high-risk customers, including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, or those conducting high-value or unusual transactions. EDD may include source-of-funds verification and ongoing monitoring.

4.2 Know Your Customer (KYC)

PassCash KYC procedures include:

1. Collection of valid government-issued identification
2. Proof of address, such as utility bills or bank statements
3. Verification of beneficial ownership for business accounts
4. Periodic review and updating of customer information

4.3 Transaction Monitoring

PassCash continuously monitors transactions to identify suspicious activity, including:

1. Large or repeated transactions
2. Transactions inconsistent with a customer's known profile
3. Cross-border transactions involving high-risk countries or entities
4. Abuse or manipulation of exchange or escrow services

4.4 Politically Exposed Persons (PEPs)

1. PEPs are identified during onboarding.
2. Enhanced due diligence is applied to PEP accounts.
3. Transactions involving PEPs are subject to continuous monitoring and Compliance Officer review.

4.5 Sanctions Screening

All customers are screened against applicable sanctions and watchlists, including:

1. Office of Foreign Assets Control (OFAC)
2. United Nations Security Council sanctions lists
3. Local and regional sanctions lists

Accounts linked to sanctioned individuals or entities are restricted or terminated immediately.

4.6 Suspicious Activity Reporting (SAR/STR)

1. Employees and agents must report suspicious activity promptly to the AML Compliance Officer.
2. The Compliance Officer reviews and files reports with the relevant Financial Intelligence Unit (FIU) where required.
3. All reports are handled confidentially to protect the integrity of investigations.

4.7 Record Keeping

PassCash maintains accurate and complete records, including:

1. Customer identification and verification documents
2. Transaction records
3. AML/CFT reports and internal investigations

Records are retained for a minimum of five (5) years or as required by applicable law.

4.8 Third-Party, Agent, and Partner Due Diligence

Where applicable, PassCash conducts due diligence on agents, merchants, and service partners to ensure they maintain appropriate AML/CFT controls and do not expose the platform to undue risk.

4.9 Employee and Agent Training

All relevant personnel receive regular AML/CFT training to:

1. Recognize suspicious activities
2. Understand reporting obligations
3. Stay informed about regulatory and policy updates

5. Risk-Based Approach

PassCash applies a risk-based approach to AML/CFT compliance.

1. Low-risk customers are subject to standard due diligence.
2. High-risk customers are subject to enhanced due diligence and increased monitoring.

Risk assessments are conducted periodically and updated as business activities evolve.

6. Governance and Oversight

6.1 AML Compliance Officer

PassCash appoints an AML Compliance Officer responsible for:

1. Overseeing AML/CFT compliance
2. Conducting risk assessments and internal reviews
3. Reporting suspicious activities to regulatory authorities

6.2 Reporting Structure

All employees and agents are required to report suspicious activities to the AML Compliance Officer immediately. Failure to report may result in disciplinary action.

6.3 Whistleblowing

PassCash provides internal channels for reporting AML/CFT concerns confidentially and without fear of retaliation.

7. Technology and Controls

PassCash uses appropriate technological controls to support AML/CFT compliance, including:

1. Automated identity verification tools
2. Transaction monitoring and alert systems
3. Sanctions and watchlist screening tools

8. Cross-Border Compliance

PassCash aligns its AML/CFT framework with:

1. Financial Action Task Force (FATF) recommendations
2. Caribbean Financial Action Task Force (CFATF) standards
3. Applicable United States regulations, including the Bank Secrecy Act

9. Non-Compliance

Failure to comply with this policy may result in disciplinary action, account suspension or termination, regulatory reporting, and legal consequences.

10. Review and Updates

This AML/CFT Policy is reviewed at least annually or when changes in laws, regulations, or business operations require updates.

Acknowledgment

All employees, contractors, agents, merchants, and partners must acknowledge and comply with this policy. Failure to do so may result in disciplinary or legal action.