Effective Date: 30 May 2025

At StraightPays ("we", "our", "the Company"), safeguarding the integrity of our financial operations is a core priority. This policy outlines the controls, procedures, and commitments we have in place to combat money laundering and the financing of terrorism, in compliance with applicable laws in Canada and the European Union.

1. Policy Statement

Our platform is dedicated to preventing the misuse of its services for illicit financial activities. We have implemented a comprehensive AML/CFT framework designed to detect and report suspicious conduct, ensure compliance with local and international regulations, and maintain our reputation as a trusted financial service provider.

This policy is binding for all personnel, agents, and affiliated entities involved in delivering our services.

2. Key Terminology

AML – Anti-Money Laundering: Legal and procedural measures aimed at preventing criminals from disguising illegally obtained funds as legitimate income.

CFT – Countering the Financing of Terrorism: Laws and controls designed to detect and restrict financial activities associated with terrorist groups or individuals.

CDD – Client Due Diligence: Identification and verification of clients and their UBOs, understanding the nature and purpose of the business relationship.

EDD – Enhanced Due Diligence: Extended verification measures applied to clients presenting higher risk, such as politically exposed persons (PEPs).

FINTRAC – Financial Transactions and Reports Analysis Centre of Canada: Canada's financial intelligence unit, responsible for AML/CFT regulatory compliance.

PEP – Politically Exposed Person: An individual who holds, or has held, prominent public positions and whose transactions require special scrutiny.

RBA – Risk-Based Approach: A structured methodology used to assess ML/TF risks and apply proportionate controls accordingly.

STR – Suspicious Transaction Report: A formal report submitted to authorities when a financial transaction is suspected to relate to money laundering or terrorist financing.

3. Identity Verification

Before establishing any relationship, we gather sufficient data to:

1. Confirm the client's legal identity.
2. Identify UBOs in the case of legal entities.
3. Clarify the source of funds.
4. Understand the purpose and nature of the relationship.

We rely on secure, verified documents and independent checks to authenticate identity. High-risk clients undergo enhanced review, which may include source of wealth declarations and senior management approval.

4. Ongoing Due Diligence

We conduct continuous due diligence to ensure that:

1. Client information remains up-to-date and relevant.
2. Significant changes in ownership, operations, or risk level are captured.
3. Enhanced KYC is triggered upon material change in client profile.
4. Additional risk-based reviews are conducted at scheduled intervals.
5. New documentation is collected where gaps or outdated records are found.
6. Additional risk-based reviews are conducted at scheduled intervals to evaluate if client risk profiles require reclassification or further investigation.
7. New documentation is collected where gaps or outdated records are found to ensure uninterrupted compliance with regulatory and internal requirements.

We reassess documentation and risk ratings throughout the relationship.

5. Transaction Oversight

To maintain operational integrity, we:

• Review transaction frequency and volumes • Set and evaluate custom thresholds • Flag and review activities outside typical behavioral patterns

Each transaction is monitored for alignment with client profiles. When necessary, we may suspend or delay transactions until additional verification is completed.

6. Risk Evaluation Process

Upon client registration, we assign a preliminary risk score based on:

1. Jurisdiction and country of residence.
2. Client's occupation or business type.
3. Exposure to public roles (PEPs).
4. Anticipated transaction behavior.

We regularly reassess risk levels and adjust monitoring levels accordingly. We reserve the right to decline business relationships that exceed our acceptable risk appetite.

7. Screening and Sanctions Checks

We systematically check all relevant parties against authoritative international lists, including:

1. United Nations Security Council.
2. European Union Consolidated Sanctions List.
3. United States OFAC (Office of Foreign Assets Control) Sanctions Lists.
4. Canada's OSFI (Office of the Superintendent of Financial Institutions) Sanctions List.

The Platform performs sanctions screening not only on clients, but also on their representatives, ultimate beneficial owners (UBOs), and related corporate entities.

We also conduct screening for adverse media to identify potential reputational risks associated with clients, their UBOs, or affiliated entities.

Screening results are logged with timestamps and investigated promptly in case of a positive match.

Our systems screen client data daily to ensure ongoing compliance. Any positive matches trigger an immediate investigation.

8. AML Officer Responsibilities

Our designated AML Compliance Officer (CO):

1. Oversees daily compliance operations.
2. Approves high-risk client onboarding.
3. Coordinates employee training.
4. Submits STRs to the relevant authorities.
5. Liaises with regulators and law enforcement.
6. Maintains AML program documentation and audits.
7. Updates risk assessments in line with emerging threats.
8. Coordinates regulatory reporting deadlines.
9. Leads periodic internal audits to verify AML control effectiveness.

The CO reports directly to executive leadership and has full independence in executing duties.

9. Suspicious Activity Escalation

Any employee who detects a suspicious transaction must escalate it internally. All suspicious activity is escalated in accordance with our internal Suspicious Activity Escalation Protocol.

Our escalation flow includes frontline reporting → compliance review → CO review and potential STR filing.

Escalated cases are documented in the compliance case management system, including decision timelines and rationale.

If justified, the CO will file an STR. We strictly prohibit tipping-off the client.

We comply with lawful requests for information from authorized agencies and regulators. This includes assistance to law enforcement upon official requests, provided in accordance with applicable legal requirement.

10. Employee Education

Our AML training program ensures all staff:

• Recognize red flags • Understand escalation protocols • Stay updated on legislative changes

Training is mandatory during onboarding and conducted annually. Refresher sessions are triggered by regulatory updates.

11. Documentation Standards

We retain:

1. KYC and verification documents for 5 years following account closure.
2. Transaction and monitoring logs for the same period.
3. STRs and any reports or communications related to AML for no less than 5 years.
4. Internal audit trails and compliance logs required under FINTRAC and EU regulations.

Retention systems are subject to regular access control reviews to ensure only authorized personnel have access.

Document integrity is protected by electronic signatures and time-stamping where applicable.

Documents may be stored in electronic or physical formats and are accessible only to authorized personnel under strict confidentiality controls.

12. Final Notes

StraightPays upholds a zero-tolerance approach to financial crime. We are fully committed to maintaining a secure and transparent financial environment.

This policy is subject to periodic review, at least annually, or earlier if required by legislative or regulatory changes.

For inquiries or support, please contact: [email protected]

Services available on this Website are operated by PlusPay under financial license No. M22171232.