Turbo pay, UAB (trading name UAB "Turbo pay", hereinafter referred to as “UAB "Turbo pay"”) is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the UAB "Turbo pay" are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to UAB "Turbo pay"’s strategy and program.

UAB "Turbo pay" has strict and transparent standards and continuously strengthens UAB "Turbo pay"’s processes so as to ensure compliance with applicable AML laws and regulations.

UAB "Turbo pay" reserves the right to reject any customer, payment or business that is not consistent with the UAB "Turbo pay" AML policy subject to the requirements of the applicable AML laws and regulations.

Adherence to Applicable AML Laws and Regulations

In accordance with AML regulations, the customer is required to provide UAB "Turbo pay" an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to the UAB "Turbo pay" additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

Monitoring for Suspicious Activity

UAB "Turbo pay"’s AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, UAB "Turbo pay" may request information regarding the transactions carried out through the customer’s account opened at UAB "Turbo pay" and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, UAB "Turbo pay" also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

AML Risk Profile

UAB "Turbo pay" AML Risk Profile is composed of products and services, customers (individuals and entities) and country risk. Within these risk categories and as a result of the global reach in providing a service UAB "Turbo pay" could be unwittingly used for the furtherance of financial crime. Financial crime – UAB "Turbo pay" must comply with legal requirements to deter and detect financial crime, which includes money laundering and terrorist financing.

Products and services.

UAB "Turbo pay" focuses on B2B services offering e-wallet and bank wire options (SEPA/SWIFT). The highest risk is Transaction risk with particular attributes, which include, but are not limited to:

1. Transaction type.
   • - Could the type of transaction be used for the purposes of money laundering or is it at a higher risk of money laundering? (e.g., Salary - low risk, Estate Agency - higher risk);
   • - Does the transaction make sense or is it overly complex given the underlying nature of the business being conducted?
   • - Does it make sense that your client has asked your firm to carry out this type of transaction? (e.g. is it within your area of expertise/local geographical area?)
2. Value of transaction.
   • - Does the value of the transaction appear to fall within the financial means of the client, given their income and savings?
3. Source of funds.
   • - Is the source of funds clear and identifiable?
   • - Are funds coming from a recognized (regulated) financial/credit institution or are they personal funds?
   • - Is any funding coming from overseas? Where from? Who from? Connection to the client?
   • - Are any of the funds being paid by a third party otherwise unconnected to the transaction?
4. Destination of funds.
   • - Does transactional behaviour match money flow declared by the client?
   • - Any indications that account is used as transit?
5. Purpose of relationship.
   • - For what purposes customer use UAB "Turbo pay" products?
   • - Is the account used for: operational purposes, settlement, trading etc?

Customers.

Risks from UAB "Turbo pay"‘s own customer base, their type of business or the ultimate beneficiary of funds needs to be considered when UAB "Turbo pay" enters and conducts business. UAB "Turbo pay" is using third-party provider „Acuity“ to conduct PEP’s and Sanctions screening.

Customers are divided into two categories: Individuals and Entities. The risk level of Individual clients will be determined by the country of residence.

The risk level of the Entity will be determined by their type of business, Age of legal entity, group structure complexity and beneficial owners, directors, and Authorised signatories risk.

Geography (Country) risk.

Identifying geographic locations that may pose a higher risk is a core component of any inherent risk assessment and the business line will seek to understand and evaluate the specific risks associated with doing business in, opening and servicing accounts, offering products and services and/or facilitating transactions involving certain geographic locations.

Geography/Country risk may also be considered together with some of the other risk factors in other risk categories, for example, in Clients for FIs, and in Products and Services for Transactions. For example, the percentage of a business division, unit or business line’s transactions with a high-risk country may provide an indication of the inherent risk from a Geography/Country perspective.

Prohibitions

UAB "Turbo pay" has no AML risk appetite for customers who engage in any of the following:

• intentional or wilfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;
• repeated unintentional or repeated accidental breaches of AML laws;
• misusing the account for the purpose of money laundering or terrorism financing;
• misusing the account for the purpose of other fraud;
• facilitating business activities which could be construed as a tax offence;
• refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in UAB "Turbo pay" AML policy.

UAB "Turbo pay" intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. Please note that UAB "Turbo pay" may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

Sanctions

UAB "Turbo pay" has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation.

UAB "Turbo pay" also has no appetite to execute transactions relating to any such natural person or legal entity being included in:

• the United Nations Security Council Sanctions List (UN);
• the Consolidated List of European Union Financial Sanctions (EU);
• sanction lists administered by the United States Office of Foreign Assets Control (OFAC), including the List of Specially Designated Nationals and Blocked Persons;
• any other sanctions list.

In addition, UAB "Turbo pay" pays particular attention to entities from countries which are on the list of non-cooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

If you have any questions regarding our AML policy, please contact our compliance@vicpayments.com