Anti-Money Laundering Policy (AML) EpinUSD is a legally established peer-to-peer ("P2P") platform that provides services for the purchase and sale of digital assets over the Internet. The company is registered as a Money Services Company by the Financial Crimes Enforcement Network. EpinUSD Anti-Money Laundering ("AML") policies and procedures are designed to prevent the blocking of illegal activities on the platform and the exploitation of users, companies, digital currencies and financial services communities by criminals. The Company complies with the requirements of the Bank Secrecy Act and related regulations and policies. As part of EpinUSD's Compliance policies, Know Your Customer ("KYC") policies and procedures are designed to enable the Company to establish a reasonable belief that it knows the true identities of the customers for whom these reviews are made. The policy applies to all users on the platform and is followed by all Company employees, consultants, officers, owners and directors. Using a risk-based approach as part of Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance, Paxful has taken the following measures: * Appointment of a Compliance Director with sufficient expertise and independence and responsible for overseeing compliance with relevant laws, regulations, standards and industry codes; * Establishing and maintaining a risk-based Know Your Customer (KYC), Customer Due Diligence (CDD) and Advanced Due Diligence (EDD) Policy; * Creation of risk-based ratings for verification of company users; * Cooperation as required by legal authorities and local legislation; * Completion of Suspicious Activity Reports (“SARs”); * Conducting Company-wide Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Foreign Assets Control Office (OFAC) trainings; * Use of various anti-fraud systems; * Continuous monitoring of rule-based transactions; * Conducting investigations using blockchain analytics; We complete Suspicious Activity Reports (“SARs”) when we know, suspect, or have reason to suspect suspicious activity is taking place on our platform. A suspicious transaction is one that is often inconsistent with the known and legitimate activities, personal activities or personal tools of the user. Our Compliance Director reviews and investigates suspicious activity to determine whether sufficient information has been collected to validate a Suspicious Activity Report. Our Compliance Director maintains records and supporting documentation of all Suspicious Activity Reports completed. The company has also adopted ongoing policies and procedures regarding U.S. Office of Foreign Assets Control (OFAC) sanctions designed to protect the platform from prohibited transactions, prohibited persons, or tax avoidance or exposure to U.S. and global sanctions. EpinUSD cooperates fully with OFAC on the Specially Designated Citizens (SDN) and Blocked Persons sanctions lists. Please see the list below for a list of risk-based banned countries that the Company has blocked from using the EpinUSD platform. OFAC banned countries Users and traffic from the following countries are banned from EpinUSD: * Burundi * Central African Republic Sanctions * Cuba * Crimea region * Iran * Iraq * Lebanon * Libya *North Korea * Somalia * South Sudan-related Sanctions * Sudan and Darfur * Syria * Venezuela * Yemen If EpinUSD has provided you with a translation of the English version of this policy, you agree that the translation is for your convenience only and that your relationship with EpinUSD will be governed solely by the English versions of this policy. In case of any inconsistency between the English version of the policy and its translation, the English version will take precedence.