Anti-Money Laundering (AML) Policy

1. Policy Overview

OZAMAPAY is committed to maintaining the highest standards of Anti-Money Laundering (AML) compliance. Our AML Policy is designed to prevent the use of our platform for money laundering, terrorist financing, and other illegal financial activities. We comply with all applicable AML laws and regulations in Haiti, the United States, and international jurisdictions in which we operate.

2. AML Compliance Program

Our AML Compliance Program includes:

• Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
• Enhanced Due Diligence (EDD) for high-risk customers
• Ongoing transaction monitoring and reporting of suspicious activity
• Customer identification verification
• Source of funds verification
• Politically Exposed Person (PEP) screening
• Sanctions list screening against OFAC and international lists
• Regular staff training on AML regulations and procedures

3. Customer Due Diligence (CDD)

As part of our onboarding process, we collect and verify information about all customers, including:

• Full legal name and date of birth
• Residential address and contact information
• Government-issued identification documents
• Source of funds and nature of business
• Expected transaction volume and patterns
• Purpose and nature of the customer relationship

4. Enhanced Due Diligence (EDD)

For customers identified as high-risk, we conduct Enhanced Due Diligence, which may include:

• Additional background verification
• Financial statement review
• Third-party reference checks
• Business structure and beneficial ownership analysis
• Enhanced ongoing transaction monitoring

5. Transaction Monitoring

We maintain an ongoing transaction monitoring program to detect suspicious activity. Monitoring includes:

• Real-time monitoring of all transactions
• Detection of unusual transaction patterns
• Threshold-based alert systems
• Behavioral anomaly detection
• Geographic risk assessment
• Currency exchange monitoring

6. Suspicious Activity Reporting

Any transactions or activities that appear suspicious are reported to relevant authorities, including the Financial Intelligence Unit (FIU) and law enforcement agencies. We maintain detailed records of all reported suspicious activities and cooperate fully with investigations.

7. Sanctions Screening

We screen all customers and transactions against:

• OFAC (Office of Foreign Assets Control) Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated List
• Other international sanctions lists
• Politically Exposed Person (PEP) databases

8. Customer Restrictions

We may refuse service to or terminate relationships with customers who:

• Are subject to sanctions or appear on restricted lists
• Engage in suspicious or illegal activities
• Refuse to provide required identification or documentation
• Appear to be structuring transactions to avoid reporting thresholds
• Are involved in high-risk jurisdictions or industries

9. Record Keeping

We maintain detailed records of all customer information, verification documents, transaction history, and compliance decisions for a minimum of five (5) years, as required by law. All records are stored securely and made available to regulatory authorities upon request.

10. Staff Training

All OZAMAPAY staff involved in customer onboarding, transaction processing, or compliance receive regular training on AML regulations, sanctions compliance, and suspicious activity detection. Training is conducted annually and updated as regulations change.