Overview of the Policy’s Importance

In the evolving landscape of financial transactions, particularly within the cryptocurrency sector, the imperative to maintain a robust Anti-Money Laundering (AML) framework is paramount. Xbancer Payment Limited recognizes the critical role that an effective AML policy plays in safeguarding the integrity of our financial system. This policy is crafted not only as a compliance measure but also as a cornerstone of our ethical responsibility to prevent the misuse of our platform for money laundering or the financing of terrorist activities. We understand that money laundering poses significant risks, including legal, reputational, and operational hazards, and therefore, we are committed to detecting, preventing, and reporting any such activities that might occur within the scope of our business operations.

• Commitment to Compliance with AML Laws and Regulations

Xbancer Payment Limited firmly commits to full compliance with all applicable anti-money laundering laws, rules, and regulations. This commitment is not just a legal obligation, but a core aspect of our corporate ethos. We operate in strict adherence to the guidelines set forth by local and international regulatory bodies, ensuring that our practices are always aligned with the latest legal standards and best practices in the industry. Our policy is continually updated to reflect changes in AML legislation and regulatory guidance, demonstrating our proactive approach to compliance. We also work closely with legal experts and advisors to ensure that our AML strategies are effective and comprehensive.

• Applicability to All Company Operations and Transactions

This AML policy is all-encompassing and applies to every aspect of our operations at Xbancer Payment Limited It governs all our business dealings, transactions, customer interactions, and partnerships. Every employee, from senior management to new hires, is expected to adhere to these guidelines in their daily activities and decision-making processes. Additionally, we require all clients, partners, and affiliated entities to engage with us under the strict observance of these AML principles. Through this universal applicability, we ensure a consistent and unwavering stance against money laundering and related financial crimes across all levels of our business.

By implementing and rigorously following this AML policy, Xbancer Payment Limited aims to maintain the highest standards of financial security and integrity, thus protecting not only our interests but also those of our clients and the broader financial community.

1.  Purpose and Scope of the AML Policy

Purpose of the AML Policy

The Anti-Money Laundering (AML) policy of Xbancer Payment Limited is fundamentally designed to prevent financial crimes that may arise within the spectrum of our services. It seeks to establish a comprehensive control system that not only detects and deters potential money laundering and terrorist financing activities but also aligns with the ethical standards expected from a reputable financial institution. The objectives of this policy are to:

1. Ensure the integrity and security of our transactional processes are inviolable and transparent.
2. Instill a culture of compliance and ethical behavior within all levels of our
3. Provide a clear and practical framework for the identification, management, and mitigation of financial crime risks.
4. Facilitate the timely detection and reporting of suspicious activities to the relevant authorities.
5. Uphold the confidence of our customers, partners, and regulatory bodies in our commitment to lawful and ethical business practices.

Scope of the AML Policy

The scope of this policy is all-encompassing and integral to our operational ethos. It is applicable, without exception, to all customers, whether individual or corporate entities, across all jurisdictions in which we operate. The policy governs all transactions, regardless of size or frequency, ensuring that each is subject to the same level of scrutiny to safeguard against illicit use of our services. Additionally, the policy extends to all business operations, including but not limited to:

1. Customer onboarding processes and ongoing due
2. Transaction monitoring and screening
3. Employee training programs and internal control
4. Partner and third-party service provider
5. Product development and service

Through the establishment of this policy, Xbancer Payment Limited aims to maintain a strong defensive stance against money laundering and related financial crimes, thereby preserving the sanctity of the financial system and contributing to the global fight against such illicit activities.

2.  Legal and Regulatory Framework

Adherence to Legal Standards

Xbancer Payment Limited is steadfast in its adherence to the prevailing legal and regulatory standards that underpin the international financial system’s defense against money laundering and terrorist financing. We are acutely aware that effective AML compliance is not static but requires vigilant alignment with evolving legal landscapes. To this end, our policy is grounded in stringent observance of, but not limited to, the following regulatory instruments:

1. The Financial Action Task Force (FATF) Recommendations, which provide an international benchmark for effective legal, regulatory, and operational
2. European Union directives and regulations pertinent to AML, notably the Anti-Money Laundering Directives (AMLDs), which we integrate into our operations to the fullest extent.
3. Local legislative acts and statutory instruments that govern the operation of cryptocurrency trading platforms and financial service providers in our

Regulatory Compliance

Our approach to regulatory compliance is proactive and comprehensive. We monitor regulatory developments continuously and assess the impact of any changes on our operations to ensure immediate and full compliance. The Company’s legal team, in conjunction with the Compliance Officer, undertakes regular reviews of our AML policy to align with any legislative updates. We also maintain an open and cooperative relationship with regulatory authorities, ensuring transparency and responsiveness to inquiries and directives.

Oversight and Enforcement

The enforcement of this legal and regulatory framework is the bedrock of our AML policy. It is the responsibility of the Compliance Officer to oversee the implementation of these regulations within the company. This oversight includes:

1. Ensuring that the company’s AML measures meet or exceed regulatory
2. Disseminating information regarding updates and changes in AML-related laws to relevant personnel within the company.
3. Working in concert with legal advisors to interpret complex regulatory requirements and translate them into actionable policies and procedures.

3. Developing an integrated compliance program that incorporates training, monitoring, and auditing to enforce adherence to these legal standards. Compliance Infrastructure

We have instituted a robust infrastructure designed to ensure compliance with the legal and regulatory requirements. This infrastructure includes:

1. Technological solutions for transaction monitoring and sanctions
2. Comprehensive record-keeping systems that align with data retention requirements stipulated by law.
3. Mechanisms for internal and external communication of AML matters, ensuring that any regulatory changes are swiftly addressed and incorporated into our operational procedures.

4.  Definitions and Key Terms

In the context of this Anti-Money Laundering (AML) policy, certain terms and definitions are utilized with specific meanings attached to them. This section serves to clarify these key terms to ensure a common understanding and consistent application throughout the company. The following are definitions of crucial AML-related terminology:

Anti-Money Laundering (AML): The set of laws, regulations, and procedures intended to prevent individuals or entities from disguising illegally obtained funds as legitimate income.

AML measures range from tracking criminal profits to imposing sanctions on non-compliance.

Customer Due Diligence (CDD): The process by which the company identifies and verifies the identity of its clients. CDD is a fundamental component of AML policy that helps to assess the risk a customer poses and the nature of their financial activities.

Enhanced Due Diligence (EDD): Additional information and scrutiny applied to customers presenting a higher risk of money laundering or terrorist financing. This includes more

in-depth monitoring and examination of the business relationships and transactions of high-risk clients.

Know Your Customer (KYC): A component of CDD, KYC refers to the processes employed to verify the identity of clients, understand their financial dealings, and ascertain the risks they may present. KYC is a critical measure in the prevention of financial crimes. Money Laundering: The illegal process of making large amounts of money generated by criminal activity, such as drug trafficking or terrorist funding, appear to have come from a legitimate source.

Terrorist Financing: The process of providing financial support to individuals or groups that engage in terrorism. This includes the funding of terrorist acts, as well as the funding of terrorist organizations.

Suspicious Activity Report (SAR): A document that financial institutions must file with the Financial Intelligence Unit (FIU) when they suspect customer involvement in money laundering or terrorist financing.

Financial Intelligence Unit (FIU): A central national agency responsible for receiving, analyzing, and transmitting disclosures of financial information concerning suspected proceeds of crime and potential terrorist financing.

Beneficial Owner: The natural person or persons who ultimately own or control a customer or the natural persons on whose behalf a transaction is conducted. This includes those persons who exercise ultimate effective control over a legal person or arrangement.

Politically Exposed Persons (PEPs): Individuals who are or have been entrusted with prominent public functions, domestically or internationally, which may make them higher-risk customers due to their position and the potential for corruption.

Sanctions Screening: The process of reviewing existing and potential business relationships to ensure

compliance with national and international sanctions lists. This includes the screening of individuals, entities, and countries subject to various trade and economic sanctions.

Correspondent Banking: Banking services provided by one bank (the correspondent bank) to another bank (the respondent bank). These services may include cash management, international wire transfers, and other cross-border transactions.

Risk-Based Approach (RBA): A method where businesses identify, assess, and understand the money laundering and terrorist financing risks to which they are exposed, and take AML measures commensurate to those risks.

Internal Controls: Processes and procedures implemented by the company to prevent, detect, and report money laundering and terrorist financing, as well as to ensure ongoing compliance with AML policy.

Compliance Officer: An individual appointed to oversee and implement the AML policy and program within the company, ensuring adherence to all legal requirements and internal procedures.

5.  Customer Identification and Verification (KYC Procedures)

Fundamentals of Customer Due Diligence

At Xbancer Payment Limited, the cornerstone of our AML framework is a robust Customer Identification and Verification process, also known as Know Your Customer (KYC). Our KYC procedures are designed to promote transparency and prevent our platform from being used to facilitate money laundering or terrorist financing.

Identification Requirements

Upon initiating a business relationship with a new customer, or when an existing relationship is deemed to require review, the company shall collect and record the following information:

1. Full legal name and any
2. Date and place of
3. Permanent residential address (not a O. Box).
4. Official personal identification number or another unique identifier issued by a government authority.
5. Contact information, including telephone number and email
6. Occupation or business

In the case of corporate entities, additional information shall be collected, including but not limited to:

1. Company name and any dba (doing business as)
2. Company registration number or tax identification
3. Registered address and principal place of
4. Full names and positions of all
5. Identities of beneficial owners and shareholders holding significant

6. Articles of Incorporation, business licenses, or other documents evidencing legal status and the nature of the business conducted.

Verification Methods

The verification of the customer’s identity shall be performed using reliable, independent source documents, data, or information. This may include:

1. Government-issued identification documents such as passports, national ID cards, or driving licenses.
2. For corporate entities, extracts from the commercial register, articles of association, and other regulatory documents.
3. Electronic verification and reference to reputable and independent sources, where applicable.

All documents, data, or information collected for the purpose of identification and verification shall be kept up-to-date and be reviewed regularly.

Ongoing Due Diligence and Monitoring

The KYC process at Xbancer Payment Limited is not a one-time event but a continuous obligation. Regular monitoring of transactions and business relationships shall be conducted to ensure that the activities are consistent with the company’s knowledge of the customer and their risk profile, including, where necessary, the source of funds.

Enhanced Due Diligence for High-Risk Categories For customers assessed as high-risk,

Enhanced Due Diligence (EDD) procedures will be employed. These may include obtaining additional identification documents, taking additional steps to verify the authenticity of the documents provided, understanding the purpose and intended nature of the business relationship, and conducting ongoing monitoring of the business relationship.

Customer Risk Assessment

Each customer will be assigned a risk profile based on a range of factors, including but not limited to geographic location, industry sector, transaction patterns, and the nature of the business activities. The risk assessment will determine the level of due diligence to be applied and the frequency of ongoing review.

Compliance Records

All records of identification, verification, and transactions will be maintained for a minimum period as required by law. These records shall be accessible for audit and review by regulatory authorities upon request.

6.  Enhanced Due Diligence for High-Risk Customers

Rationale for Enhanced Due Diligence

At Xbancer Payment Limited, we recognize that certain customer relationships pose higher risks than others. Enhanced Due Diligence (EDD) is a more thorough process than the standard KYC procedures and is applied to high-risk customers to mitigate the elevated risks of money laundering and terrorist financing associated with these relationships.

Identification of High-Risk Customers

High-risk customers are identified based on several factors that may include, but are not limited to:

1. Geographical risk, where customers are residents of, or conduct business in, countries known to have high levels of corruption, money laundering, or terrorist
2. Customer risk, including involvement with sectors that are prone to financial crime or individuals who are politically exposed persons (PEPs).
3. Product, service, and transaction risk, particularly where the nature of the business presents greater opportunities for money laundering.

EDD Measures

For customers categorized as high-risk, the following EDD measures are employed:

1. Obtaining Additional Information:
   • Detailed information about the customer’s business and source of
   • Enhanced scrutiny of the business activities and the rationale behind the transactions.
2. Verification of Information:
   • Independent verification of the customer’s identity and information provided, using reliable, publicly available sources.
   • For legal entities or arrangements, obtaining information about the reputation of the company and the quality of supervision to which it is
3. Understanding Ownership and Control Structure:
   • Identifying the beneficial owners and taking reasonable measures to verify their identities.
   • Assessing the control structure of corporate entities, trusts, and other complex legal arrangements.
4. Ongoing Monitoring:
   • Continuous monitoring of transactions to detect any that do not conform to the customer’s profile or business rationale.
   • Periodic review of the customer relationship and risk
5. Approval of Senior Management:
   • Transactions or new accounts involving high-risk customers will require approval from senior management before establishing or continuing the business
   • Senior management will also be involved in the ongoing oversight of these high-risk relationships.
6. Documentation and Record-Keeping:
   • Comprehensive documentation of all EDD measures taken, including decision-making processes and findings of the enhanced
   • Keeping records of EDD activities accessible for regulatory examinations and audits.
7. Risk Mitigation:
   • Implementing appropriate risk management controls for high-risk customers, including limits on the types of transactions they can conduct or enhanced transaction monitoring protocols.
   • Where necessary, conducting enhanced ongoing due diligence on all transactions associated with high-risk customers.

Review and Update of EDD Measures

EDD measures and customer risk profiles are not static and require regular review to ensure they remain current and appropriate. The frequency of these reviews will be proportionate to the risk level of the customer. Any changes in the customer’s business operations, ownership, or other relevant circumstances will trigger a re-evaluation of the risk profile and may necessitate additional EDD measures.

7.  Monitoring of Transactions and Suspicious Activity Reporting

Continuous Transaction Monitoring

Xbancer Payment Limited upholds a rigorous transaction monitoring program designed to detect and prevent illicit financial activity across its platform. Our commitment to the principles of Anti-Money Laundering (AML) necessitates vigilant oversight of all financial

transactions. We employ state-of-the-art technology combined with analytical methods to ensure continuous surveillance and analysis of transactional data.

Identification of Suspicious Activity

The transaction monitoring system is configured to flag activities that may suggest money laundering, such as:

1. Unusual transaction patterns that deviate significantly from a customer’s established behavior.
2. Transactions that are complex or unusually large, with no clear economic or lawful purpose.
3. Funds transfers to and from jurisdictions known to pose a higher risk of money laundering or terrorist financing.
4. Any activity that is consistent with known methods of money laundering or suggests criminal activity.

Responsibilities in Detecting Suspicious Activities

It is the responsibility of all employees to remain alert to risks and anomalies in customer behavior or transaction patterns. Staff members are trained to recognize indicators of suspicious activity and are mandated to report such observations to the designated Compliance Officer promptly.

Suspicious Activity Report (SAR) Filing

Upon the detection of suspicious activity, the following steps will be taken:

1. Immediate internal reporting to the Compliance Officer for further
2. The Compliance Officer will review and investigate the activity to determine whether it warrants the filing of a SAR.
3. If a decision is made to file a SAR, the report will be submitted to the relevant Financial Intelligence Unit (FIU) without delay and in accordance with legal and regulatory requirements.
4. All SAR filings will be done confidentially, with no disclosure to the parties involved, to avoid tipping off.

Record-Keeping of Suspicious Activities

Detailed records of all investigated transactions, regardless of whether they resulted in a SAR, will be maintained. This includes documentation of the investigation process, supporting evidence, and the rationale for the decision made.

Ongoing Training and Support

To support the monitoring of transactions and reporting of suspicious activities, Xbancer Payment Limited provides ongoing training to all employees. This training ensures that staff members are knowledgeable about AML compliance, understand the latest trends in financial crime, and are proficient in utilizing the monitoring systems in place. Regulatory Compliance and Cooperation

Xbancer Payment Limited is committed to full regulatory compliance in all jurisdictions in which it operates. This includes adhering to reporting deadlines, cooperating with law enforcement and regulatory bodies, and responding to any requests for additional information related to SARs or AML compliance.

Review and Enhancement of Monitoring Systems

Our transaction monitoring systems and procedures are subject to continuous review and enhancement to address emerging threats and to incorporate advancements in technology. The Compliance Officer, in coordination with the IT and Security departments, ensures that our systems remain effective and aligned with best practices in AML monitoring.

8.  Record Keeping and Data Protection

Principles of Record Retention

Xbancer Payment Limited recognizes the vital importance of meticulous record keeping in fulfilling its Anti-Money Laundering (AML) obligations. Maintaining comprehensive records is not only a regulatory requirement but also an integral part of our commitment to AML compliance. Our record-keeping practices are designed to ensure that we can promptly respond to requests for information from customers or regulatory authorities.

Scope of Records Maintenance

Our record-keeping procedures encompass all documentation obtained through Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transactions, and Suspicious Activity Reports (SARs). The specific types of records maintained include, but are not limited to:

1. Customer identification and verification
2. Account files and business
3. Records of all financial transactions, including the nature and date of the transaction, the parties involved, and the amount and currency involved.
4. Documentation of compliance processes and decisions, including SAR filings and supporting evidence for decisions not to file a SAR when suspicious activity has been investigated.
5. Records of internal audits, compliance reviews, and AML training Data Protection Compliance

In addition to complying with AML record-keeping requirements, Xbancer Payment Limited adheres to applicable data protection laws and regulations. We are committed to

ensuring the confidentiality, integrity, and security of all customer and transaction data. To this end, we implement stringent security measures, including encryption, access controls, and regular security audits, to prevent unauthorized access to or leakage of sensitive information.

Retention Period

In line with legal and regulatory mandates, all records are retained for a minimum specified period, usually five years, following the completion of the transaction or the end of the business relationship. The retention period may be extended if requested by a regulatory authority or in response to legal proceedings or ongoing investigations.

Accessibility of Records

Records are stored in a manner that allows for timely retrieval. This means implementing organized electronic storage systems with indexed records to ensure that any data required by regulatory bodies can be accessed without undue delay.

Destruction of Records

Upon the expiration of the retention period, records are disposed of in a secure and irreversible manner to protect sensitive information from potential misuse. The destruction of records will be conducted in accordance with established procedures that are designed to maintain the confidentiality and privacy of the data throughout the disposal process.

Audit and Review of Record-Keeping Practices

Our record-keeping practices are subject to regular internal and external audits to ensure compliance with AML regulations and data protection laws. These audits also serve to evaluate the effectiveness of our record-keeping procedures and to identify areas for improvement.

Responsibility for Record-Keeping

The responsibility for ensuring that record-keeping procedures are followed rests with the Compliance Officer, who will provide oversight and training to relevant staff members. All employees are expected to understand their role in maintaining accurate and complete records and to comply with these procedures as part of their daily responsibilities.

9.  Role and Responsibilities of the Compliance Officer

Designation of the Compliance Officer

Xbancer Payment Limited affirms the critical role of the Compliance Officer in enforcing our Anti-Money Laundering (AML) policy. This individual holds a key position within the company, bearing the primary responsibility for the oversight of all AML compliance-related activities. 

Qualifications and Authority

The Compliance Officer is appointed based on their expertise in AML regulations, experience in compliance, and understanding of the cryptocurrency industry. They are empowered with full authority to implement the AML program, oversee its execution, and ensure adherence across all departments and levels of the company.

Responsibilities

The Compliance Officer’s responsibilities are comprehensive and include:

1. Policy Development and Updates:
   • Drafting, maintaining, and updating the AML policy and related procedures to comply with evolving legal and regulatory standards.
2. Training and Guidance:
   • Conducting regular AML training sessions for all staff
   • Providing ongoing advice and guidance to ensure understanding and adherence to AML requirements.
3. Risk Assessment:
   • Continually assessing the company’s exposure to money laundering and terrorist financing risks and adapting the AML program accordingly.
4. Compliance Monitoring:
   • Establishing effective internal controls and monitoring systems to prevent , detect, and report potentially suspicious activities.

• Regularly reviewing and testing these controls to assess their
  
  5. Reporting:
     • Serving as the principal point of contact for all AML matters, including liaising with regulatory bodies and law
     • Filing Suspicious Activity Reports (SARs) and other mandatory reports with financial intelligence units and other competent authorities.
  6. Record-Keeping:
     • Ensuring that records related to customer due diligence, account monitoring, and SARs are maintained accurately and in compliance with regulatory requirements.
  7. Regulatory Liaison and Reporting:
     • Acting as the liaison between Xbancer Payment Limited and regulatory agencies on matters related to AML compliance.
     • Reporting to senior management and the board of directors on AML compliance and the effectiveness of the AML program.
  8. Audit and Review:
     • Facilitating internal and external audits of the AML

• Implementing corrective actions based on audit findings to strengthen compliance measures.

Accountability

The Compliance Officer is accountable to the board of directors and senior management, providing regular reports on the state of the company’s AML compliance and advising on significant legal and regulatory developments that may affect the company’s operations. Support and Resources

Xbancer Payment Limited is committed to providing the Compliance Officer with the necessary resources, access to all relevant information, and support from management to fulfill their role effectively.

10.  Employee Training and Awareness

Importance of AML Training

Xbancer Payment Limited places utmost importance on the continuous education and awareness of its employees regarding Anti-Money Laundering (AML) policies and procedures. We believe that a well-informed workforce is our first line of defense against financial crime.

Training Objectives

The objectives of our AML training program are to:

1. Educate employees about the nature of money laundering and terrorist financing, including the underlying criminal activities that generate illicit
2. Ensure that all employees understand the legal and regulatory framework governing AML efforts and their personal responsibilities within these
3. Equip employees with the knowledge to recognize and properly handle suspicious activities or transactions that could potentially be related to money laundering or terrorist financing.
4. Foster a compliance culture where AML practices are integrated into the daily operations of our business.

Training Curriculum

The curriculum for AML training is comprehensive, covering topics such as:

1. Fundamentals of AML and KYC regulations and
2. The process of identifying and verifying customer
3. Procedures for monitoring customer transactions and
4. Methods for reporting suspicious
5. Case studies and examples of money laundering
6. The role of the Compliance Officer and the AML compliance
7. Updates on new AML-related laws, regulations, and best Training Frequency and Methods AML training sessions are conducted regularly and are mandatory for all employees. New hires receive AML training as part of their onboarding process. Refresher courses are provided annually to ensure that all staff remain current with evolving regulations and practices. Additionally, specialized training is given when there are significant changes in AML laws or when new AML-related threats and trends emerge.

The training methodologies include interactive sessions, workshops, webinars, and e-learning modules. These are designed to cater to different learning styles and to ensure maximum retention of information.

Assessment and Compliance Tracking

Post-training assessments are conducted to measure employee comprehension and the effectiveness of the training program. Attendance and completion records are meticulously kept as part of our compliance tracking efforts.

Continuous Awareness

Beyond formal training sessions, continuous awareness is promoted through regular communications such as newsletters, bulletins on recent AML developments, and alerts regarding new methods of money laundering detected in the industry.

Accountability and Reporting

Employees are encouraged to report any AML concerns to the Compliance Officer without fear of reprisal. A clear, confidential reporting mechanism is in place for this purpose.

11.  Risk Assessment and Management

Commitment to Risk Management

Xbancer Payment Limited is committed to a robust Risk Assessment and Management program as a fundamental part of our Anti-Money Laundering (AML) framework.

Understanding and mitigating the risks associated with money laundering and terrorist financing is essential for maintaining the integrity of our financial services.

Risk Assessment Procedures

Our risk assessment process is designed to be comprehensive and continuous, identifying potential risks associated with customers, products, services, and geographies. The procedures include:

1. Identification of Risks:
   • Systematic identification of inherent AML risks associated with each segment of our customer base, financial products, delivery channels, and the geographic regions of operation.
2. Risk Evaluation and Categorization:
   • Evaluation of identified risks based on their likelihood and potential impact, leading to a categorization of risks as low, medium, or
3. Implementation of Controls:
   • Application of mitigating controls to manage and mitigate identified risks effectively. This includes Enhanced Due Diligence (EDD) for higher risk categories and simplified measures for lower risks.
4. Monitoring and Reporting:
   • Continuous monitoring of the risk environment and the effectiveness of the control measures. Regular reporting to the Compliance Officer and senior management on the risk assessment outcomes.

Risk Management Strategies

Our risk management strategies are tailored to address the specific risks identified during the assessment phase. These strategies may include, but are not limited to:

1. Adjusting customer due diligence measures based on risk

categorization. 2. Applying enhanced scrutiny and monitoring to high-risk customers, including Politically Exposed Persons (PEPs) and those from high-risk jurisdictions.

3. Limiting or refusing to engage in certain business relationships or transactions when the risks cannot be adequately mitigated.
4. Regular updates to AML policies and procedures to reflect changes in the risk profile of the company.

Role of Senior Management

Senior management plays a critical role in risk assessment and management, providing strategic direction and ensuring that sufficient resources are allocated to AML risk mitigation efforts. Their oversight ensures that risk management processes are integrated into the company’s overall risk management framework.

Employee Engagement

All employees are made aware of the company’s risk profile related to money laundering and are trained to recognize and respond to risks appropriately. They are an integral part of the risk management process and are encouraged to report potential risks to the Compliance Officer.

Review and Update

The risk assessment process is not static; it is reviewed and updated regularly to account for new threats, emerging trends, and changes in the operational environment. Significant events, such as the launch of new products or expansion into new markets, also trigger a review of the risk assessment.

Conclusion

The Risk Assessment and Management program is a key component of our commitment to AML compliance. Xbancer Payment Limited proactively identifies and manages AML risks, thereby ensuring the stability and security of our operations and the financial system at large.

12.  Audit and Review of AML Procedures

Commitment to Rigorous Oversight

Xbancer Payment Limited recognizes that regular audits and reviews are essential to the strength and effectiveness of our Anti-Money Laundering (AML) procedures. We are committed to a rigorous oversight process that ensures our AML controls are both compliant with legal requirements and effective in practice.

Audit Objectives

The objectives of our AML audit program include:

1. Verification of Compliance:
   • To verify that AML procedures are fully compliant with applicable laws and regulations.
2. Assessment of Effectiveness:
   • To assess the effectiveness of the current AML procedures in preventing, detecting, and reporting potential money laundering
3. Identification of Weaknesses:
   • To identify any weaknesses or gaps in the AML framework and recommend enhancements.
4. Risk Management Validation:
   • To validate the adequacy of the company’s risk management related to money laundering and terrorist financing.

Audit Frequency and Scope

Our AML audits are conducted on a regular basis, at a minimum annually, or more frequently if circumstances dictate, such as changes in regulatory requirements or the emergence of new risks. The scope of the audit encompasses all aspects of the AML program, including:

1. Customer identification and verification
2. Due diligence and enhanced due diligence
3. Transaction monitoring systems and reporting
4. Employee training and awareness
5. Record-keeping and data protection

Internal and External Audits

The AML audit program involves both internal and external audits:

1. Internal Audits:
   • Conducted by our internal audit team, which operates independently of the AML operational functions to ensure an unbiased
2. External Audits:
   • Performed by third-party auditors with AML expertise to provide an external perspective on the adequacy of our AML procedures and controls.

Audit Reporting

Upon completion of an audit, a detailed report is prepared that includes:

1. Findings on the compliance and effectiveness of AML
2. Recommendations for improvements or corrective
3. An action plan with specific timelines for addressing any deficiencies Management Review

The findings of AML audits are reviewed by senior management and the Compliance Officer. Decisions on the implementation of recommendations are taken promptly to ensure that AML procedures remain robust and responsive to the latest compliance standards.

Continuous Improvement

Audit findings are used as a tool for continuous improvement. The company ensures that lessons learned are integrated into the AML program and that best practices are adopted across all operations.

13.  Reporting Obligations and Procedures

Adherence to Reporting Standards

Xbancer Payment Limited is firmly committed to fulfilling its reporting obligations under the Anti-Money Laundering (AML) regulatory framework. Timely and accurate reporting of suspicious activities is not only a legal mandate but also a corporate responsibility that we take with the utmost seriousness.

Scope of Reporting Obligations

Our reporting obligations include, but are not limited to:

1. Suspicious Activity Reports (SARs):
   • Filing SARs with the relevant Financial Intelligence Unit (FIU) whenever there is a suspicion or reasonable grounds to suspect that funds are the proceeds of a criminal activity or are related to terrorist
2. Currency Transaction Reports (CTRs):
   • Reporting currency transactions over a specified threshold, as required by applicable laws and regulations.
3. International Funds Transfer Reports:
   • Reporting cross-border fund transfers that meet or exceed designated thresholds.
4. Compliance Reports:
   • Submitting periodic reports that may be required by regulatory bodies to demonstrate compliance with AML obligations.

Responsibility for Reporting

The Compliance Officer is responsible for ensuring that all reports to regulatory authorities are filed in accordance with the required standards and within stipulated time frames. All employees of Xbancer Payment Limited are required to report any suspicious activities to the Compliance Officer without delay.

Procedures for Reporting

Upon identification of a potentially reportable transaction or activity, the following procedures are enacted:

1. Notification:
   • Immediate notification to the Compliance Officer for initial
2. Investigation:
   • Conducting a preliminary investigation to ascertain the validity of the suspicion and gather all pertinent information.
3. Documentation:
   • Thoroughly documenting the findings and decisions made during the
4. Filing:
   • The Compliance Officer, upon confirming the suspicion, will file the SAR or other required reports with the appropriate authority.

Confidentiality in Reporting

All reports are filed confidentially to protect the integrity of the investigations and to comply with statutory requirements. Employees

are prohibited from disclosing the fact that a SAR or any related report has been filed, except as directed by the Compliance Officer or as required by law.

Training on Reporting Procedures

To ensure effective compliance with reporting obligations, all relevant employees receive training on the identification and reporting of suspicious activities. This training includes guidance on maintaining confidentiality and the legal ramifications of non-compliance.

Record-Keeping of Reports

Records of all reports filed, as well as information and documentation related to the reports, are retained in accordance with legal and regulatory requirements. This ensures that the company can demonstrate its compliance efforts and provide information for any subsequent investigations by authorities.

Audit of Reporting Practices

The company’s reporting practices are audited regularly to ensure accuracy, completeness, and timeliness. The audit also assesses the effectiveness of the reporting procedures and recommends improvements as necessary.

14.  Penalties for Non-Compliance and Internal Disciplinary Actions

Commitment to Compliance

At Xbancer Payment Limited, adherence to Anti-Money Laundering (AML) regulations and our internal policies is non-negotiable. We recognize the severe implications of

non-compliance, not only for our company but also for the broader financial system. Therefore, we have established clear penalties for non-compliance and a framework for internal disciplinary actions.

Legal and Regulatory Penalties

Non-compliance with AML laws and regulations can result in severe legal and regulatory consequences, including but not limited to:

1. Monetary Fines:
   • Substantial fines imposed by regulatory authorities for breaches of AML regulations.
2. Criminal Liability:
   • Possible criminal charges against the company and individual employees, depending on the severity of the non-compliance.

3. Reputational Damage:
   • Damage to the reputation of Xbancer Payment Limited, potentially impacting customer trust and business relationships.
4. Operational Restrictions:
   • Restrictions or the revocation of business licenses, limiting the company’s ability to operate.

Internal Disciplinary Actions

In addition to legal consequences, internal disciplinary actions will be taken against employees who violate our AML policy, procedures, or any related laws and regulations. These actions include:

1. Formal Warnings Issuing formal warnings to employees as an initial response to minor or first-time violations.
2. Mandatory Training: Requiring additional AML training to reinforce understanding of
3. Suspension: Temporary suspension from duties, especially in cases where ongoing investigations are necessary.
4. Termination of Employment: Dismissal from the company in cases of severe, intentional, or repeated non-compliance.
5. Referral for Legal Action: Referring cases of serious misconduct to law enforcement or regulatory authorities.

Accountability and Responsibility

Every employee at Xbancer Payment Limited is responsible for understanding and adhering to our AML policies and procedures. The accountability for compliance does not solely rest on the individual employee

but also on management and supervisory staff, who are expected to enforce these policies and ensure their team’s compliance.

Procedure for Handling Violations

Upon detection of a potential violation, the following steps are undertaken:

1. Investigation:
   • A thorough investigation is conducted to ascertain the facts of the
2. Review:
   • The Compliance Officer, in consultation with Human Resources and legal advisors, reviews the findings of the investigation.
3. Decision:
   • A decision on the appropriate disciplinary action, based on the severity and nature of the violation.

Reporting and Documentation

All violations and disciplinary actions are documented and reported to senior management. This ensures transparency and accountability in handling non-compliance issues.

Preventative Measures

In addition to punitive actions, Xbancer Payment Limited focuses on preventative measures, including regular training and clear communication of our AML policies, to minimize the risk of non-compliance.

The establishment of firm penalties for non-compliance and a structured approach to internal disciplinary actions reflect Xbancer Payment Limited’s unwavering commitment to upholding the highest standards of AML compliance. Through these measures, we ensure the integrity of our operations and protect our reputation as a responsible financial services provider.

15.  Amendments and Policy Updates

Commitment to Dynamic Compliance

Xbancer Payment Limited recognizes that the landscape of Anti-Money Laundering (AML) compliance is dynamic, with continuous developments in legal requirements and best practices. In response, we maintain a proactive stance in updating and amending our AML policy to reflect these changes and ensure ongoing compliance.

Process for Policy Amendments

The process for updating our AML policy includes:

1. Continuous Monitoring:
   • Regular monitoring of legal and regulatory developments in AML compliance, both domestically and internationally.
2. Evaluation:
   • Thorough evaluation of how changes in laws, regulations, and industry best practices impact our existing AML policy and procedures.
3. Recommendations:
   • The Compliance Officer, in consultation with legal advisors and senior management, formulates recommendations for amendments or updates to the policy.
4. Approval:
   • Proposed amendments are presented to the board of directors or a designated committee for review and approval.
5. Implementation:
   • Upon approval, changes are promptly implemented into the AML policy and associated procedures.
6. Communication:
   • Clear and effective communication of any changes to all employees, along with relevant training and support to ensure understanding and compliance.
7. Documentation:
   • Documentation of all amendments, including the rationale and approval process, is maintained for audit and regulatory review

Stakeholder Involvement

In updating the AML policy, we engage with various stakeholders, including:

1. Legal and Compliance Teams:
   • To ensure that the amendments align with legal requirements and best practices.
2. Operational Departments:
   • To assess the practical implications and operational feasibility of the proposed changes.
3. Senior Management:
   • For strategic oversight and to ensure alignment with the overall business objectives.

Feedback Mechanism

We encourage feedback from employees, customers, and other stakeholders on our AML policy. This feedback is considered during the review process to make the policy more effective and user-friendly.

Review Schedule

The AML policy is formally reviewed at least annually. However, ad-hoc reviews may occur in response to significant regulatory changes, major corporate events, or the emergence of new risks or threats.

Conclusion

The regular amendment and updating of our AML policy demonstrate Xbancer Payment Limited’s dedication to maintaining the highest standards of AML compliance. This adaptive approach ensures that our policies remain effective and relevant in a rapidly evolving regulatory landscape.

Reaffirmation of Commitment

Xbancer Payment Limited hereby reaffirms its unwavering commitment to the highest standards of Anti-Money Laundering (AML) compliance. This AML policy, in its comprehensive scope and detail, embodies our dedication to upholding the integrity of the financial system and our steadfast resolve in combating money laundering and terrorist financing.

Corporate Responsibility and Ethical Standards

We recognize that our responsibility extends beyond mere compliance with legal requirements. Our AML policy is a reflection of our ethical standards and our commitment to responsible corporate citizenship. We understand that in safeguarding our operations against financial crime, we contribute to a more secure and transparent global financial environment. Continuous Improvement and Adaptation

In a rapidly evolving financial landscape, particularly in the realm of cryptocurrency, we acknowledge the need for continuous improvement and adaptation. Xbancer Payment Limited is committed to regularly reviewing and updating our AML policies and procedures to stay abreast of emerging risks, regulatory changes, and advancements in technology.

Collaboration and Transparency

We pledge to maintain a collaborative approach with regulatory authorities, law enforcement, and our partners in the financial sector. Transparency, open communication,

and cooperation are key principles that guide our interactions with these stakeholders. We believe that through collective efforts, the fight against money laundering and terrorist financing can be more effective and far-reaching.

Empowerment and Accountability

This policy empowers each member of Xbancer Payment Limited, from the board of directors to the newest employees, with the knowledge and responsibility to actively participate in our AML efforts. We hold ourselves accountable for implementing these practices in our daily operations and decision-making processes.

Contact Information for Queries

For any queries or clarifications regarding our AML policy, stakeholders are encouraged to contact our Compliance Officer, whose details are provided in our internal communication channels. We welcome inquiries and feedback as part of our commitment to continuous improvement and transparency.

Closing Statement

In closing, Xbancer Payment Limited stands firmly in its role as a diligent guardian against financial crime. We are proud of our robust AML policy and the culture of compliance it fosters within our organization. Together, we ensure that our business practices not only meet

regulatory standards but also align with our corporate values of integrity, responsibility, and ethical conduct.

Through this policy, Xbancer Payment Limited asserts its position as a responsible, vigilant, and ethical participant in the global financial marketplace, dedicated to maintaining the trust and confidence of our clients, partners, and regulatory bodies.

Registered Name: XBANCER PAYMENT LTD Registration number: M23142214

Address: 1238 – 1771 ROBSON ST VANCOUVER, BC, CANADA V6G3B7

Contact Number: +1 (707) 760-7850 Email : info@xbancer.com

Director : Ms. Ruchi Rathor