AML / KYC Disclosure Notice

Compliance Program

Paymenture maintains compliance procedures designed to support:

• AML compliance;
• sanctions compliance;
• fraud prevention;
• blockchain compliance;
• Travel Rule obligations; and
• cybersecurity monitoring.

Identity Verification

Paymenture and its Service Providers may require:

• identity verification;
• business verification;
• beneficial ownership verification;
• source of funds verification;
• sanctions screening;
• wallet ownership verification; and
• enhanced due diligence.

Transaction Monitoring

Paymenture may monitor:

• transactions;
• wallets;
• counterparties;
• blockchain activity;
• API activity;
• device activity; and
• behavioral indicators.

Paymenture may utilize:

• blockchain analytics providers;
• sanctions screening providers;
• fraud monitoring systems; and
• cybersecurity monitoring tools.

Regulatory Reporting

Paymenture and its Service Providers may:

• cooperate with regulators;
• cooperate with law enforcement;
• file Suspicious Activity Reports ("SARs");
• freeze transactions;
• restrict accounts; or
• disclose information where required by law.

Freeze & Restriction Rights

Paymenture reserves the right to:

• reject onboarding;
• freeze assets;
• delay settlement;
• restrict transactions;
• terminate accounts; or
• prohibit access to jurisdictions or counterparties

where compliance or sanctions risks arise.

Record Retention

Paymenture may retain:

• transaction records;
• blockchain data;
• compliance records;
• communications; and
• monitoring information

for as long as reasonably necessary to comply with law and manage risk.