Effective Date: April 1, 2026 · MSB Registration No. C10001686

AML/KYC policy

INTRODUCTION

PayPoint Solutions Ltd. (hereinafter referred to as the "Company" or "PayPoint") is a registered Money Services Business (MSB) in Canada, regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number C10001686. The Company is subject to and required to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17) and all associated regulations, principles, and guidelines, which set out obligations for customer identification and verification, record-keeping, and reporting of suspicious transactions.

This AML/KYC Policy establishes the Company's framework for fulfilling these obligations and maintaining the integrity of the financial system.

DEFINITIONS

For the purposes of this Policy, the following terms have the meanings set out below:

"We", "us", "our": refer to PayPoint Solutions Ltd..
"Services": means any services, subject to the Terms and Conditions, offered by PayPoint.
"Customer", "you", "your": refers to any person who has or seeks to establish a business relationship with PayPoint, as defined in the Terms and Conditions.
AML (Anti-Money Laundering): a set of activities, procedures, and regulatory requirements designed to protect the integrity of the financial system and prevent the misuse of financial institutions for unlawful purposes.
CFT (Combating the Financing of Terrorism): measures required of financial institutions and other regulated entities to prevent, detect, and report activities that may be connected to the financing of terrorism.
CDD (Customer Due Diligence): a process used to identify and verify the identity of Customers and to assess the risk of money laundering or terrorist financing associated with them.
EDD (Enhanced Due Diligence): a higher level of scrutiny applied in circumstances involving elevated risk, including dealings with high-risk Customers or transactions, or with persons from high-risk jurisdictions.
KYC (Know Your Customer): a process used to verify the identity of Customers and to understand their financial activities in order to assess the risk associated with the Customer relationship.
PEP (Politically Exposed Person): an individual who holds, or has previously held, a prominent public position, such as head of state, senior government official, or high-ranking military officer. PEPs include their immediate family members and close associates.
Employee: any person performing duties for PayPoint under an employment contract, mandate agreement, cooperation agreement, or similar arrangement.
Money Laundering: the process of disguising the proceeds of illegal activities as legitimate funds, typically through a series of transactions designed to conceal their true origin.
Transaction: an act initiated by the Customer involving the placement, transfer, or withdrawal of funds, as defined in the Terms and Conditions.

PURPOSE

The purpose of this AML/KYC Policy is to prevent PayPoint from being used as a vehicle for money laundering, terrorist financing, or any other financial crime. To achieve this, the Company has established policies, procedures, and internal controls designed to comply fully with all applicable AML/KYC regulations and to promote a culture of compliance throughout the organization.

SCOPE

This Policy applies to all Customers and to all transactions conducted through the PayPoint website and platform at https://www.paypointmoney.ca/, and to all Employees of PayPoint.

By creating an account on our platform and using our Services, the Customer acknowledges and agrees to comply with this AML/KYC Policy.

RISK ASSESSMENT

PayPoint conducts a risk assessment of each Customer and associated transactions to evaluate the risk of money laundering or terrorist financing. This assessment takes into account the Customer's background and profile, the nature and purpose of the transaction, and any relevant geographic or industry-specific risk factors. Risk assessments are reviewed on an ongoing basis and updated as circumstances change.

SANCTIONS AND POLITICALLY EXPOSED PERSONS (PEPs)

PEP status is treated as a significant risk factor in our Customer risk analysis. PayPoint screens all Customers against international sanctions lists and PEP databases using third-party screening tools. Customers identified as PEPs, or as being subject to applicable sanctions, are subject to enhanced scrutiny and additional verification procedures in accordance with applicable law and regulatory guidance.

TRANSACTION MONITORING AND CARD VERIFICATION

PayPoint monitors and analyzes Customer transaction patterns on an ongoing basis. Unusual or suspicious activity is treated as an indicator of elevated risk and may trigger a request for additional information or documentation, including evidence of source of funds, the purpose of the transaction, and the intended use of the transferred amounts.

PayPoint requires verification of the Customer's payment card to confirm the identity of the cardholder and ensure legitimate use. Card verification processes may include cardholder information checks, verification of the Card Verification Value (CVV) or Card Verification Code (CVC), Address Verification System (AVS) checks, and two-factor authentication.

CUSTOMER DUE DILIGENCE (CDD)

As part of our standard CDD process, all Customers are required to provide the following information:

Full legal name
Date of birth
Residential address
Telephone number
Email address
Government-issued identification document (e.g., national ID card or passport)
Proof of address (e.g., utility bill or bank statement dated within the last three months)
Information about the Customer's business or financial activities, as applicable

We reserve the right to request additional information or documentation at any time as required to fulfil our CDD obligations under applicable law and regulatory guidance.

ENHANCED DUE DILIGENCE (EDD)

In circumstances where a heightened risk of money laundering or terrorist financing is identified, PayPoint may apply Enhanced Due Diligence measures. EDD may involve obtaining supplementary information or documentation about the Customer, the transaction, the source of funds, and the intended purpose of the transfer. EDD is applied in accordance with the risk assessment framework and applicable regulatory requirements.

SUSPICIOUS ACTIVITY REPORTING

PayPoint has established internal controls for the identification and reporting of suspicious activity. Where suspicious activity is identified, it is reported to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. All Employees are required to report any suspicious activity they become aware of to the designated Compliance Officer without delay.

RECORD-KEEPING

PayPoint maintains comprehensive records of all Customer information, transactions, and suspicious activity reports in accordance with applicable laws and regulations. Records are retained for a minimum period of five (5) years from the date of the transaction or the end of the business relationship, whichever is later. All Customer data is collected and stored in accordance with the PayPoint Privacy Policy.

EMPLOYEE TRAINING

All Employees of PayPoint receive training on AML/KYC regulations and our internal compliance policies and procedures. Training is provided at the time of onboarding and on an ongoing basis as required to ensure continued awareness of regulatory obligations and emerging risks.

COMPLIANCE AND POLICY REVIEW

PayPoint regularly reviews and assesses the effectiveness of this Policy and its overall compliance with AML/KYC regulations. This Policy may be updated from time to time. All changes take effect immediately upon publication on our website. Customers are encouraged to review this Policy periodically to remain informed of any updates.

CONSEQUENCES OF NON-COMPLIANCE

Non-compliance with our AML/KYC requirements may result in termination of the business relationship with the Customer. Circumstances that may lead to termination include:

Failure to Complete CDD: where a Customer fails to provide required information, provides false or incomplete information, or refuses to cooperate with the CDD process, the Company may terminate the business relationship.
Suspicious Activity: where suspicious activity is detected in a Customer's account that cannot be adequately explained, the Company may terminate the business relationship and report the matter to FINTRAC.

For any enquiries regarding this AML/KYC Policy, please contact us at:

PayPoint Solutions Ltd.
Address: 1907 Baseline Rd, Unit 104, Ottawa, ON, K2C 0C7, Canada
E-mail: support@pay-point.net

Effective Date: April 1, 2026