Anti-Money Laundering Policy

Effective Date: March 20, 2025

1. Policy Statement

WhapayInc ("Whapay") and its subsidiaries, including FCM Payments Solutions S.A.S. (CUIT 30-71689742-3), are committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy applies to all business operations across Argentina, Brazil, and the United States.

Whapay maintains zero tolerance for money laundering, terrorist financing, sanctions evasion, and all forms of financial crime.

2. Regulatory Framework

Our AML program is designed to comply with:

• Argentina: Ley 25.246 (Prevention of Money Laundering and Terrorist Financing), UIF (Unidad de Información Financiera) regulations, and BCRA payment services regulations.
• Brazil: Lei 9.613/1998 (Anti-Money Laundering Law), COAF (Conselho de Controle de Atividades Financeiras) regulations, and Central Bank of Brazil guidelines.
• United States: Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and OFAC sanctions requirements.
• International: Financial Action Task Force (FATF) Recommendations.

3. Know Your Customer (KYC)

3.1 Client Identification

Before establishing a business relationship, Whapay conducts thorough identification and verification of all clients, including:

• Legal entity verification (certificate of incorporation, articles of association)
• Identification of beneficial owners (individuals owning or controlling 25% or more)
• Verification of directors and authorized signatories
• Business activity assessment and expected transaction profile

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to higher-risk clients, including:

• Politically Exposed Persons (PEPs) and their close associates
• Clients in high-risk jurisdictions as identified by FATF
• Complex ownership structures
• Clients with unusual transaction patterns

3.3 Ongoing Monitoring

Client information is reviewed and updated periodically, with the frequency determined by the client's risk classification.

4. Transaction Monitoring

Whapay employs automated and manual transaction monitoring systems to detect suspicious activity, including:

• Transactions inconsistent with the client's known business profile
• Unusual patterns of cross-border transfers
• Structuring or splitting of transactions to avoid reporting thresholds
• Transactions involving high-risk jurisdictions
• Rapid movement of funds with no apparent business purpose

5. Sanctions Screening

All clients and transactions are screened against applicable sanctions lists, including:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated List
• Argentina's UIF lists
• Brazil's COAF lists

6. Suspicious Activity Reporting

When suspicious activity is identified, Whapay files reports with the appropriate authorities:

• Argentina: Reportes de Operación Sospechosa (ROS) to the UIF
• Brazil: Comunicação de Operação Suspeita to COAF
• United States: Suspicious Activity Reports (SARs) to FinCEN

Whapay strictly prohibits tipping off clients about the filing of suspicious activity reports.

7. Record Keeping

All client identification records, transaction records, and compliance documentation are maintained for a minimum of five (5) years from the end of the business relationship or the date of the transaction, or longer as required by applicable law.

8. Training

All employees receive AML/CTF training upon hiring and on an annual basis. Training covers the identification of suspicious activity, reporting obligations, and regulatory updates.

9. Compliance Officer

Whapay has appointed a designated Compliance Officer responsible for the implementation and oversight of this AML policy. The Compliance Officer reports directly to the CEO and has independent authority to escalate matters as necessary.

10. Policy Review

This policy is reviewed and updated at least annually, or more frequently as required by changes in applicable laws, regulations, or business activities.

11. Contact

For compliance inquiries, contact our Compliance team at compliance@whapay.com.

WhapayInc
101 W 15th Street
New York, NY 10011
United States