Bank Secrecy Act and Anti-Money Laundering Compliance Program

Welcome! Thank you for visiting Payloo Ltd, a financial services platform operated by Payloo Ltd ("we," "our," or "Payloo"), located at 16 Yekmalyan Street, Belize City, Belize. Payloo Ltd has developed a Bank Secrecy Act and Anti-Money Laundering Compliance Program ("BSA/AML Program") designed to maintain compliance with applicable laws and regulations relating to anti-money laundering (AML) and counter-terrorist financing (CTF). This includes, but is not limited to:

• Establishing robust internal policies, procedures, and controls to combat any attempted use of Payloo for illegal or illicit purposes and to ensure basic customer protections under applicable consumer protection laws;
• Complying with relevant AML/CTF regulations and guidance, including those applicable in Armenia and other jurisdictions where we operate;
• Filing Suspicious Activity Reports ("SARS");
• Filing Currency Transaction Reports ("CTRs");
• Maintaining comprehensive records of transactions and other transfers;
• Employing a Bank Secrecy Act Officer ("BSAO") responsible for the implementation and oversight of our BSA/AML Program;
• Executing Know Your Customer ("KYC") procedures on all customers;
• Performing regular, independent audits of our BSA/AML Program;
• Following record retention requirements; and
• Implementing a compliance training program for all new and existing employees.

Policies and Procedures

Our BSA/AML Program has been reviewed and approved by our Board of Directors (the "Board"). It is regularly reviewed and, if necessary, revised to ensure compliance with applicable rules, regulations, and policies. Payloo Ltd operates under the regulatory oversight of relevant authorities in Armenia and complies with international AML/CTF standards as applicable to its operations.

Internal Controls

We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations. These include, but are not limited to, employee training, our Customer Identification Program ("CIP"), the filing of SARs and CTRs, as well as other reporting requirements and audits, as outlined on this page.

Training

All of our employees, officers, and Board members receive regular BSA/AML training, including position-specific training. They must complete this training at least once every twelve (12) months. New employees receive training within thirty (30) days of their start date. All documentation related to compliance training—including materials, tests, results, attendance, and dates—is maintained. Our compliance training program is updated as necessary to reflect current laws and regulations.

Bank Secrecy Act Officer

The Bank Secrecy Act Officer ("BSAO") is responsible for coordinating and monitoring day-to-day compliance with our BSA/AML Program. The BSAO is required to report any violations directly to our CEO and the Board. Additionally, the BSAO is responsible for recording and filing SARs and CTRs and performing a BSA/AML Program audit at least annually.

Customer Identification

Our Customer Identification Program ("CIP") is a critical component of our BSA/AML Program. It helps us verify the identities of our customers, detect suspicious activity in a timely manner, and prevent fraud.

Account Opening Process

To open an account and use Payloo, your identity must be verified, authenticated, and checked against government watchlists, including international sanctions lists such as the Specially Designated Nationals List ("SDN List") published and updated by the Office of Foreign Assets Control ("OFAC"). Failure to complete any of these steps will result in your inability to use Payloo.

Individual Customer

Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:

• Email address;
• Mobile phone number;
• Full legal name;
• Government-issued identification number (e.g., passport number or national ID number);
• Date of birth ("DOB");
• Proof of identity (e.g., passport, driver's license, or government-issued ID);
• Home address (not a mailing address or P.O. Box); and
• Additional information or documentation as determined by our Compliance Team.

Non-Armenian customers may be required to provide additional proof of identity (e.g., passport or government-issued ID) and any further documentation as required under applicable laws and risk assessments. If you successfully meet and complete our CIP requirements, we will provide you with account opening agreements electronically.

Institutional Customer

Prior to opening an account for an institutional customer, we attempt to collect, verify, and authenticate the following information:

• Institution's legal name;
• Tax identification number or any comparable government-issued identification number;
• Full legal name (of all account signatories and beneficial owners);
• Email address (of all account signatories);
• Mobile phone number (of all account signatories);
• Address (principal place of business and/or other physical location);
• Proof of legal existence (e.g., certified articles of incorporation, certificate of formation, unexpired government-issued business license, trust instrument, or other comparable legal documents as applicable);
• Contact information of owners, principals, and executive management (as applicable);
• Proof of identity (e.g., passport, driver's license, or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
• Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).

If your institution successfully meets and completes our CIP requirements, we will provide you with account opening agreements electronically.

Suspicious Activity/Currency Transaction Reports Process

We file SARs if we know, suspect, or have reason to suspect suspicious activities have occurred by, at, or through Payloo. A suspicious transaction is often one that is inconsistent with a customer's known and legitimate business, personal activities, or personal means. Our Compliance Department performs transaction monitoring to help identify unusual patterns of customer activity. The BSAO is responsible for reviewing and investigating suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.

In addition, any currency transactions exceeding a determined threshold are reported via a CTR filing, in accordance with applicable regulations. Our BSAO is responsible for maintaining records and supporting documentation of all SARs and CTRs that have been filed.

BSA/AML Program Audit

Payloo's Internal Audit function is responsible for overseeing the independent assessment of our BSA/AML Program at least annually. The results are presented to our Board.

Contact Us

If you have questions or concerns regarding our BSA/AML Program, please feel free to contact us at:

Email: [email protected]

Address: Payloo Ltd, 16 Yekmalyan Street, Belize City, Belize