AML Policy

1. Purpose and Scope

BoazPay is committed to the highest standards of anti-money laundering (AML) compliance and combating the financing of terrorism (CFT). This Anti-Money Laundering Policy ("AML Policy") establishes the framework by which BoazPay identifies, prevents, and reports suspicious financial activity in connection with the merchant processing and ISO agent services we provide.

This policy applies to all BoazPay staff, agents, partners, and any third parties acting on our behalf. Compliance with this policy is mandatory and non-negotiable.

2. Regulatory Framework

BoazPay operates in compliance with applicable AML/CFT legislation and regulatory guidance, including but not limited to:

• The Bank Secrecy Act (BSA) — United States
• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations — United Kingdom
• EU Anti-Money Laundering Directives (AMLD4/5/6)
• Financial Action Task Force (FATF) Recommendations
• OFAC Sanctions Programs — U.S. Department of the Treasury
• Card network rules (Visa, Mastercard) related to fraud and financial crime

3. Know Your Customer (KYC) Program

All merchant applicants and ISO agents are subject to a rigorous Know Your Customer (KYC) verification process prior to onboarding. Our KYC program includes:

• Verification of business registration documents and corporate structure
• Identity verification of all beneficial owners holding 25% or more equity
• Collection and verification of government-issued photo identification
• Verification of business address and contact information
• Assessment of business type, industry, and expected transaction patterns
• Review of processing history, chargeback rates, and prior account terminations

We perform enhanced due diligence (EDD) on higher-risk merchants, including those operating in higher-risk jurisdictions, those with complex ownership structures, or those processing high volumes of cross-border transactions.

4. Risk Assessment

BoazPay applies a risk-based approach to AML compliance. Each merchant and agent application is assessed against a risk scoring matrix that considers:

• Industry/vertical risk (e.g., crypto, gaming, adult, forex)
• Geographic risk (country of incorporation, owner nationality, customer base)
• Transaction profile risk (volume, average ticket, cross-border ratio)
• Chargeback history and fraud indicators
• PEP (Politically Exposed Person) status of beneficial owners
• Adverse media and negative news screening results

5. Sanctions Screening

All applicants, beneficial owners, and counterparties are screened against applicable sanctions lists prior to onboarding and on an ongoing basis, including:

• OFAC Specially Designated Nationals (SDN) list
• EU Consolidated Sanctions List
• UN Security Council Consolidated List
• HM Treasury Financial Sanctions List (UK)

Any match against a sanctions list will result in immediate suspension of services and reporting to the appropriate authorities. BoazPay does not conduct business with sanctioned individuals, entities, or jurisdictions.

6. Transaction Monitoring

BoazPay and its acquiring bank partners maintain ongoing transaction monitoring programs designed to detect unusual or suspicious activity. Monitoring parameters include:

• Transaction volumes and values that deviate significantly from established baselines
• Unusual geographic patterns or high concentrations of cross-border transactions
• Elevated chargeback rates or refund anomalies
• Structuring — repeated transactions just below reporting thresholds
• Multiple accounts linked to the same beneficial owner or IP address
• Sudden spikes in transaction frequency or average ticket size

7. Suspicious Activity Reporting

Where suspicious activity is identified, BoazPay will file a Suspicious Activity Report (SAR) or equivalent report with the relevant financial intelligence unit (e.g., FinCEN in the US, NCA in the UK) as required by law. Tipping off — disclosing to a customer that a SAR has been filed — is strictly prohibited.

All staff members who identify suspicious activity must report it to the designated Compliance Officer immediately. Failure to report known or suspected suspicious activity is a serious disciplinary matter and may constitute a criminal offense.

8. Record Keeping

BoazPay retains all KYC documentation, transaction records, and compliance-related correspondence for a minimum of five (5) years following the end of a business relationship, or seven (7) years where required by applicable law. Records are stored securely and made available to regulatory authorities upon lawful request.

9. Training and Awareness

All BoazPay employees, agents, and partners with client-facing or financial roles are required to complete AML/CFT training annually. Training covers:

• Recognition of money laundering typologies relevant to payment processing
• KYC procedures and escalation protocols
• Sanctions screening and red flag identification
• Internal reporting obligations and SAR procedures
• Legal consequences of non-compliance

10. Governance and Compliance Officer

BoazPay has designated a Chief Compliance Officer (CCO) responsible for overseeing the implementation, monitoring, and updating of this AML Policy. The CCO reports directly to senior management and has the authority to escalate compliance concerns to the board level. This policy is reviewed at least annually and updated as required by regulatory changes.

11. Reporting and Contact

To report a compliance concern, suspicious activity, or request a copy of our full internal AML/CTF program documentation, contact:

BoazPay — Compliance Department
Email: legal@boazpay.com
Wyoming, USA