Anti-Money Laundering Policy

1. Policy Statement

PepPayAI is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy establishes the framework for our compliance with the Bank Secrecy Act (BSA), USA PATRIOT Act, and FinCEN regulations.

2. Know Your Customer (KYC)

Merchant Onboarding:

• Legal business name and registration
• Business address verification
• Beneficial owner identification (25%+ ownership)
• Government-issued ID of principals
• Business description and website

Enhanced Due Diligence is applied for high transaction volumes, high-risk jurisdictions, or unusual patterns.

3. Transaction Monitoring

We monitor for:

• Transactions inconsistent with stated business purpose
• Rapid movement of funds
• Transactions with sanctioned jurisdictions
• Structuring to avoid reporting thresholds
• Transactions with no apparent economic purpose

4. Sanctions Compliance

All users are screened against:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Sanctions List
• EU Consolidated List

Prohibited Jurisdictions: North Korea, Iran, Syria, Cuba, Crimea region, and other OFAC-sanctioned regions.

5. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with FinCEN when transactions of $5,000+ involve suspected illegal activity, are designed to evade reporting, have no apparent lawful purpose, or involve potential money laundering.

6. Recordkeeping

We maintain for minimum 5 years:

• Customer identification records
• Transaction records
• SAR filings and documentation
• AML training records
• Compliance audit reports

7. Training

All employees receive AML training covering regulatory requirements, red flag identification, reporting obligations, and consequences of non-compliance. Annual refresher training is mandatory.

8. Enforcement

Violations of this policy may result in account suspension or termination, reporting to law enforcement, and civil or criminal penalties.

9. Contact

AML Compliance: compliance@peppayai.com