AML / KYC Policy

1. Program Foundation

Ace Payment Services, Inc. maintains a written Anti-Money Laundering (AML) Compliance Program as required under the Bank Secrecy Act (BSA). The program includes the following core elements: internal policies, procedures, and controls; designation of a compliance officer; ongoing employee training; and independent testing of the AML program.

2. Customer Identification Program (CIP)

All customers must complete our Customer Identification Program before accessing our services. We collect and verify the following information for all customers:

• Full legal name
• Date of birth
• Residential address (not a P.O. Box)
• Government-issued identification number (Social Security Number for U.S. persons; taxpayer identification number or passport number for non-U.S. persons)
• Government-issued photo identification document

We verify this information through documentary and non-documentary methods, which may include third-party identity verification services. We will notify customers when identity verification cannot be completed and services will not be extended until verification is satisfactorily completed.

3. Know Your Customer (KYC) Standards

In addition to our CIP requirements, we conduct customer due diligence (CDD) on all customers. This includes:

• Understanding the nature and purpose of the customer relationship
• Establishing a risk profile for each customer
• Conducting enhanced due diligence (EDD) for higher-risk customers, including Politically Exposed Persons (PEPs) and customers with complex ownership structures
• Ongoing monitoring of customer relationships and transactions

4. Transaction Monitoring

We monitor customer transactions on an ongoing basis to identify patterns or activity that may be inconsistent with the customer's profile or that may indicate suspicious activity. Our monitoring program includes:

• Automated transaction monitoring alerts
• Review of transaction patterns for unusual activity
• Comparison of transactions against customer risk profiles
• Escalation procedures for flagged transactions

5. Suspicious Activity Reporting (SAR)

We file Suspicious Activity Reports (SARs) with FinCEN when we know, suspect, or have reason to suspect that a transaction involves funds from illegal activity, is designed to evade BSA reporting requirements, lacks a lawful purpose, or is not the sort of transaction that the customer would normally be expected to conduct. We do not notify customers when a SAR has been or may be filed in connection with their account or transactions.

6. Currency Transaction Reporting (CTR)

We file Currency Transaction Reports (CTRs) with FinCEN for transactions in currency (cash) that exceed $10,000 in a single business day, as required by law. We do not structure transactions to avoid CTR filing requirements, and we do not assist customers in structuring transactions for this purpose.

7. OFAC Compliance

We screen all customers and transactions against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) and other applicable sanctions lists. We do not conduct business with individuals or entities on these lists or with countries subject to comprehensive sanctions programs.

8. Recordkeeping

We maintain all required records in accordance with BSA requirements, including records of customer identification, transactions, and suspicious activity. Records are retained for a minimum of five (5) years, or longer as required by applicable law.

9. No Structuring

It is a federal crime to structure or attempt to structure transactions to avoid BSA reporting requirements. Ace Payment Services, Inc. will not facilitate structuring and will report suspected structuring to FinCEN. Accounts suspected of structuring activity will be subject to review and potential termination.