Anti-Money Laundering & Counter-Terrorist Financing Policy

1. Client Identification (KYB/KYC)

Before a merchant account is fully activated, we require verification of both the business and the individuals who control it:

• Business verification: business registration details, incorporation documents, and a description of the business's activity.
• Beneficial ownership: identification of the natural person(s) who ultimately own or control the business, consistent with EU beneficial-ownership transparency requirements.
• Supporting documentation: proof of business address, banking or processing history, and any further documents reasonably requested to complete verification.

We may decline to activate, or may suspend, an account where verification cannot be completed to our satisfaction, or where submitted documentation appears altered, inconsistent, or fraudulent.

2. Risk-Based Approach

We apply a risk-based approach to onboarding and ongoing monitoring, taking into account factors such as the business's country of registration and operation, the nature of goods or services sold, and expected transaction volumes. Businesses connected to jurisdictions identified by the European Commission as high-risk third countries for AML purposes, or subject to applicable EU or UN sanctions regimes, are subject to enhanced due diligence and, where required by law, are declined entirely.

3. Sanctions and PEP Screening

We screen merchants and their beneficial owners against applicable sanctions lists (including EU and UN consolidated lists) and politically exposed person (PEP) indicators as part of onboarding, and on an ongoing basis thereafter. A confirmed sanctions match results in immediate account restriction; a PEP match triggers enhanced due diligence before an account can proceed.

4. Transaction Monitoring

We monitor transaction activity for patterns inconsistent with a merchant's stated business activity or expected volume, including unusually large or structured transactions. Where activity raises a reasonable suspicion of money laundering or terrorist financing, we may request additional information, place a hold on the transaction pending review, or restrict the account while the matter is assessed.

5. Reporting Obligations

Where we identify activity that gives rise to a reasonable suspicion of money laundering or terrorist financing, we are obliged under Polish law to report it to Poland's General Inspector of Financial Information (Generalny Inspektor Informacji Finansowej, GIIF). We are legally prohibited from informing a client that a report has been made or that they are subject to investigation ("tipping off").

6. Record Keeping

We retain identification documents, beneficial-ownership records, and transaction data for the period required under applicable AML law, generally for at least five years following the end of a business relationship or the completion of an occasional transaction, and longer where required by a competent authority in connection with an active investigation.

7. Compliance Oversight

We maintain internal responsibility for AML/CTF compliance, including periodic review of this policy against changes in applicable law and regulatory guidance. This policy is reviewed and updated as needed to reflect those changes.

8. Contact

Questions about this policy, or requests related to an account under compliance review, can be sent to support@axiomepayments.com, or by post to:

Undercover Payments sp. z o.o., ul. Bartycka 22B/21A, 00-716 Warszawa, Mazowieckie, Poland. Registration Number: 0001069394. Website: https://axiomepayments.com.