PAY4Y POLICY IN RELATION TO ANTI-MONEY LAUNDERING (AML)

Money laundering is defined as making it lawful to possess, use or dispose of funds obtained as a result of the Commission of a crime, that is, transferring them from the shadow, informal economy to the official economy in order to be able to use these funds openly and publicly. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms ' knowledge or suspicion.

In response to the large scale and consequences of money laundering, PAY4Y has implemented systems and procedures that are designed to combat money laundering. Our company strives to prevent money laundering and any proceeds obtained by illegal means.

The AML policy is designed to prevent money laundering by complying with European anti-money laundering standards. This AML Policy sets minimum standards that must be met and includes:

- Appoint a money laundering reporting officer (MLRO) who has a sufficient level of seniority and independence, and who is responsible for overseeing compliance with relevant legislation, regulations, rules, and industry guidelines;

- Develop and maintain a risk-based approach (RBA) to assess and manage the money laundering risks faced by a firm;

- Implementing and maintaining customer verification (CDD) and KYC identification procedures;

- Interaction with relevant law enforcement agencies, as appropriate;

- Keeping relevant records for the minimum set periods;

- Provide training and awareness raising to all relevant staff.

THE POLICY OF SANCTIONS:

PAY4Y does not allow transactions with individuals, companies and countries that are included in various sanctions lists So PAY4Y will check the United Nations, European Union and other sanctions lists in all jurisdictions in which we operate.