Anti-Money Laundering (AML) Policy

1. Introduction

UNIVERSAL PAYMENT NETWORK LIMITED (hereinafter referred to as “the Company”) is fully committed to the prevention of money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines the Company's framework to detect, prevent, and report such activities in compliance with applicable laws, regulations, and international standards.

2. Purpose

The purpose of this AML Policy is to establish internal controls, procedures, and responsibilities designed to ensure compliance with anti-money laundering laws and best practices, including the recommendations of the Financial Action Task Force (FATF), and applicable national regulatory frameworks.

3. Scope

This policy applies to all employees, directors, officers, contractors, and agents of the Company. It covers all products, services, and business lines and must be adhered to in all jurisdictions where the Company operates.

4. Customer Due Diligence (CDD)

The Company shall conduct thorough customer due diligence (CDD) prior to establishing any business relationship. This includes the identification and verification of all clients, beneficial owners, and controlling parties. Required documentation may include government-issued identification, proof of address, and corporate registration documents.

5. Enhanced Due Diligence (EDD)

For customers and transactions that present a higher risk, the Company will apply Enhanced Due Diligence (EDD) measures. These measures include gathering additional information, conducting background checks, increased monitoring, and obtaining senior management approval prior to proceeding.

6. Ongoing Monitoring

The Company will conduct continuous monitoring of customer relationships and transactions to identify any unusual or suspicious activity. Monitoring systems will be designed to detect red flags and unusual patterns.

7. Suspicious Activity Reporting

All employees must report suspicious activities to the designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for evaluating the report and, if necessary, submitting a Suspicious Transaction Report (STR) to the appropriate authorities in a timely manner.

8. Record Keeping

The Company shall retain all relevant AML documentation, including customer identification records, transaction histories, and internal reports for at least the minimum period required by law. Records must be readily available for inspection by regulatory authorities.

9. Training and Awareness

All employees will receive ongoing training on AML obligations, the recognition of suspicious activities, and the proper internal reporting procedures. Training programs will be regularly reviewed and updated to remain current with legal and regulatory developments.

10. Policy Governance

The AML Policy will be reviewed and approved by the Board of Directors at least annually. Updates may be made as necessary to reflect changes in regulations, business operations, or risk exposure.

11. Approval

This Anti-Money Laundering Policy is approved by the Board of Directors of UNIVERSAL PAYMENT NETWORK LIMITED and is effective as of May 29, 2025.