AML/CFT Policy and Program Overview

eUSD maintains a comprehensive Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) compliance framework designed in accordance with applicable regulatory requirements. Our AML/CFT program is based on a risk-based approach and is supported by internal compliance governance to prevent the misuse of our card products for money laundering, terrorist financing, fraud, sanctions violations, or other financial crimes.

1. Governance and Compliance Oversight

eUSD has established an independent Compliance Function responsible for AML/CFT compliance, sanctions screening, fraud prevention, and regulatory reporting obligations.

A designated Compliance Officer oversees the implementation and effectiveness of the AML/CFT program, including:

1. AML/CFT policy implementation and maintenance
2. Review and escalation of suspicious activity
3. Sanctions and PEP screening oversight
4. Ongoing compliance monitoring
5. Internal training and awareness programs
6. Periodic policy review and independent testing

The Board and senior management retain overall responsibility and oversight of the AML/CFT framework under a three-lines-of-defense model.

2. Customer Due Diligence (CDD / KYC)

eUSD applies a risk-based Customer Due Diligence (CDD) framework to all customers prior to card issuance.

KYC verification services are performed through a third-party provider, Coinface, which supports the onboarding process as a technology and identity verification service provider.

Coinface provides the following KYC-related services:

1. Identity document verification
2. Facial recognition and liveness detection
3. Data extraction and validation
4. Automated screening integration support

All KYC results generated through Coinface are subject to review and approval by eUSD’s Compliance Function.

As part of the CDD process, the following checks are performed:

1. Identity verification (KYC)
2. Sanctions screening
3. Politically Exposed Person (PEP) screening
4. Adverse media screening
5. Risk assessment based on geography and user profile
6. Intended usage and transaction purpose review (where applicable)

Anonymous, fictitious, or sanctioned individuals are strictly prohibited from onboarding.

3. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk customers, including but not limited to:

1. Politically Exposed Persons (PEPs)
2. High-risk jurisdictions
3. High-value or unusual transaction profiles
4. Complex customer profiles or ownership structures
5. Elevated risk indicators identified during onboarding or monitoring

EDD measures may include:

1. Senior management approval
2. Additional identity or financial documentation
3. Enhanced risk assessment review
4. Increased ongoing monitoring frequency

4. Transaction Monitoring

eUSD conducts ongoing monitoring of customer card activity to detect unusual or suspicious behavior, including:

1. Transaction frequency and velocity monitoring
2. Large or unusual spend patterns
3. Cross-border transaction activity
4. ATM withdrawals and cash-like usage
5. Merchant category risk analysis
6. Structuring or fragmentation of transactions

Alerts generated by monitoring systems are reviewed by the Compliance team for investigation and escalation where necessary.

5. Sanctions and PEP Screening

All customers are screened against relevant sanctions and risk lists, including:

1. OFAC sanctions lists
2. United Nations sanctions lists
3. EU and UK sanctions lists
4. Applicable local regulatory lists
5. Politically Exposed Persons (PEP) databases
6. Internal watchlists

Screening is conducted at onboarding and continuously throughout the customer lifecycle.

6. Suspicious Activity Reporting (SAR)

Where suspicious activity is identified:

1. Accounts may be restricted, suspended, or closed
2. Cases are escalated to the CO for review
3. Internal investigation is conducted
4. Where required, Suspicious Activity Reports (SAR/STR) are filed via the appropriate regulated entity
5. Our partners are notified in accordance with contractual obligations

Strict confidentiality and anti-tipping-off controls are maintained at all times.

7. Record Keeping and Audit

Customer due diligence records, transaction history, screening results, and compliance decisions are securely maintained in accordance with applicable regulatory retention requirements.

The AML/CFT program is subject to:

1. Periodic internal compliance reviews
2. Independent audit or testing
3. Diligence reviews

Ongoing updates based on regulatory changes and risk assessments

8. Third-Party Risk Management

eUSD engages third-party service providers to support certain compliance and operational functions, including KYC verification services provided by Coinface.

All third-party providers are subject to due diligence, contractual obligations, and ongoing performance monitoring to ensure compliance with AML/CFT requirements and data protection standards.

Notwithstanding the use of third-party providers, eUSD retains full responsibility and accountability for the effectiveness of its AML/CFT program, including customer onboarding decisions and ongoing compliance obligations.