Anti-Money Laundering and Counter-Terrorist Financing Policy
ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY
VERSION DATE: APRIL 2026
1. INTRODUCTION
1.1 This is the Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CTF”) Policy of Valens Pay.
1.2 Valens Pay is a trading name, website and platform brand used in connection with onboarding, compliance, payment-related, fintech and digital asset-related services made available by the relevant operating and/or regulated entity identified for the applicable service and jurisdiction.
1.3 This AML and CTF Policy describes the standards, controls and principles applied in connection with the Valens Pay platform, including the customer due diligence, sanctions screening, transaction monitoring, suspicious activity escalation and related compliance measures applied by the relevant service entity and its authorised partners.
2. INFORMATION ABOUT US
2.1 Valens Pay is a trading name and platform brand used in connection with services made available by entities within the Valens Pay group and/or authorised third-party service providers.
2.2 The Valens Pay group includes, among others:
Valens Pay Inc.
30 N Gould St Ste R
Sheridan, WY 82801
United States
Company No. 2026-001939891
Incorporated April 2, 2026
2.3 Valens Pay Inc. is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN), United States.
Valens Pay Limited
302-540 Lawrence Avenue
Kelowna V1Y 6L7
British Columbia
Canada
Company No. BC1278918
2.4 Valens Pay Global Limited acts as the parent company of the Valens Pay group.
2.5 As used in this AML and CTF Policy, “Company”, “Valens Pay”, “we”, “us” or “our” means, as applicable, Valens Pay Inc. and/or other affiliated entities within the Valens Pay group, depending on the nature of the service, the relevant customer relationship, the applicable jurisdiction and the operational setup.
2.6 For the avoidance of doubt, Valens Pay is a brand and platform and is not itself a separate regulated legal entity.
2.7 Any concerns regarding AML and CTF matters, onboarding, compliance reviews, sanctions restrictions, source of funds checks or suspicious activity should be addressed through the official support and compliance channels made available on the Valens Pay platform or website.
3. AML / CTF FRAMEWORK
3.1 Money laundering is the process by which the proceeds of crime are disguised so that they appear to derive from legitimate sources. Terrorist financing involves the use or movement of funds or other assets in support of terrorism or terrorist activity, whether or not such funds originate from criminal activity.
3.2 Financial technology platforms, payment-related services, digital asset services and onboarding environments may be exposed to money laundering, terrorist financing, sanctions evasion, fraud and related financial crime risks.
3.3 In response to those risks, the Company applies AML and CTF controls designed to prevent the misuse of the platform, services, infrastructure and customer relationships for unlawful purposes.
3.4 The Company’s AML and CTF controls are based on applicable laws, regulations, risk-based compliance standards, internal policies and relevant international standards, including risk-based customer due diligence, sanctions screening, beneficial ownership identification, transaction monitoring, suspicious activity reporting, recordkeeping and staff training.
3.5 The Company is committed to maintaining systems and controls reasonably designed to prevent the platform and related services from being used to facilitate financial crime.
4. PURPOSE OF THIS POLICY
4.1 This AML and CTF Policy sets out the minimum standards and principles which apply to the Valens Pay platform and related services and includes, among other things:
a) the appointment of appropriate compliance oversight personnel, including AML reporting responsibility where required;
b) the establishment and maintenance of a risk-based approach to assessing and managing money laundering, terrorist financing, sanctions and related financial crime risks;
c) the application of customer due diligence (“CDD”), know-your-customer (“KYC”) and enhanced due diligence (“EDD”) procedures where appropriate;
d) the implementation of ongoing monitoring, including review of customer activity and transactional behaviour;
e) the maintenance of procedures for internal escalation and external reporting of suspicious activity where required;
f) the maintenance of appropriate records for the legally required periods; and
g) training and awareness measures for relevant employees, contractors and compliance personnel.
4.2 It is prohibited to provide any product or service, or to process any transaction, where doing so would breach applicable sanctions laws, AML/CTF rules, fraud controls or internal risk policies.
4.3 The Company reserves the right to reject any customer, transaction, payment flow, merchant relationship, business model or use case that is not consistent with this AML and CTF Policy, even where the activity may not be expressly prohibited by law.
5. MAIN OBJECTIVES
5.1 The main objectives of this AML and CTF Policy are to:
a) combat and prevent money laundering, terrorist financing, sanctions evasion, fraud and related financial crime;
b) prevent misuse of the platform, services and related infrastructure for unlawful or high-risk activity;
c) establish and maintain a risk-based approach to assessing and managing AML/CTF risks;
d) establish and maintain risk-based CDD, KYC and EDD procedures, including for higher-risk customers and politically exposed persons (“PEPs”);
e) establish and maintain sanctions controls and prohibited business controls;
f) monitor customer activity and transaction patterns on an ongoing basis;
g) establish procedures for the internal escalation and external reporting of suspicious activity where appropriate;
h) maintain appropriate records and audit trails; and
i) provide relevant AML/CTF training and awareness to appropriate personnel.
6. COMPANY COMMITMENT
6.1 The Company is committed to:
a) accepting only those customers whose identity can be established and verified to an appropriate standard;
b) taking reasonable steps to understand the customer, beneficial owner, business activity and expected use of the services;
c) taking reasonable steps to establish the legitimacy of source of funds and, where appropriate, source of wealth;
d) not opening or maintaining anonymous accounts or accounts in fictitious names;
e) applying a risk-based approach to customer acceptance, onboarding and ongoing monitoring;
f) identifying, investigating and where appropriate escalating suspicious activity;
g) screening customers, counterparties and transactions against sanctions, PEP and adverse media criteria where applicable;
h) maintaining records appropriate to the nature and complexity of the customer relationship; and
i) providing regular compliance training and guidance to relevant personnel.
6.2 The Company may decline, suspend, restrict or terminate any relationship or transaction where the information provided is incomplete, inconsistent, unverifiable or otherwise unacceptable from an AML/CTF, sanctions, fraud or risk perspective.
7. CUSTOMER DUE DILIGENCE
7.1 As part of its legal and compliance obligations, the Company is required to identify the applicant for business, the customer, any beneficial owner and, where relevant, any authorised person or controller, and to verify that such person is who they claim to be.
7.2 The Company must also assess whether the customer is acting on behalf of another person, establish the purpose and intended nature of the business relationship, and monitor the relationship on an ongoing basis.
7.3 To meet these obligations, the Company applies customer due diligence measures designed to help determine whether a customer falls within its risk appetite and to build a sufficient understanding of the customer’s business, activity profile and intended use of the platform.
7.4 These due diligence measures may include:
a) identification and verification of the applicant for business;
b) identification and verification of beneficial owners, controllers, authorised signatories and relevant connected parties;
c) determination of whether the applicant is acting as principal or on behalf of another person;
d) obtaining information regarding the purpose and intended nature of the business relationship;
e) establishing expected transaction patterns or account use;
f) conducting ongoing monitoring of the relationship;
g) obtaining information on source of funds and, where appropriate, source of wealth; and
h) ensuring the applicant satisfies the applicable customer acceptance criteria.
7.5 The Company is strictly prohibited from keeping anonymous accounts or accounts in fictitious names.
8. RISK-BASED APPROACH
8.1 The Company applies a risk-based approach to AML and CTF compliance.
8.2 This means that the level of due diligence, monitoring, scrutiny and approval applied to a customer, transaction or business relationship may vary depending on risk factors including, but not limited to:
a) customer type;
b) jurisdiction and geographic exposure;
c) ownership and control structure;
d) industry and business model;
e) expected transaction volume and payment flows;
f) digital asset exposure;
g) product or service type;
h) delivery channel;
i) sanctions, PEP and adverse media exposure; and
j) any unusual, inconsistent or unexplained activity.
8.3 Where higher risk is identified, the Company may apply enhanced due diligence, request additional documentation, require senior compliance review, impose restrictions, reject activity or terminate the relationship.
9. PROHIBITIONS
9.1 The Company has no AML/CTF risk appetite for customers or counterparties who engage in, facilitate or are reasonably suspected of engaging in any of the following:
a) intentional or reckless breaches of AML, CTF, sanctions or fraud-related laws or regulations;
b) repeated breaches of AML or compliance obligations;
c) use of an account, wallet, platform or service for money laundering, terrorist financing, sanctions evasion or fraud;
d) tax evasion facilitation or deliberate concealment of beneficial ownership;
e) refusal to provide sufficient information or documentation to satisfy compliance requirements;
f) use of false, misleading, altered or stolen documentation;
g) use of nominees, intermediaries or structures designed primarily to obscure ownership or transaction purpose; or
h) any activity prohibited by applicable law, regulation, partner policy or internal risk policy.
9.2 The Company also has no or limited risk appetite, depending on the circumstances, for customers, business models, payment flows or counterparties involving prohibited or high-risk sectors, including but not limited to:
a) unlicensed charities, NGOs or donation collection structures;
b) illegal drugs, drug paraphernalia or unlawful controlled substances;
c) illegal pharmaceuticals or unlicensed drug-related activity;
d) bribery, corruption or unlawful facilitation payments;
e) pyramid schemes, Ponzi schemes or get-rich-quick schemes;
f) sale of government IDs or falsified documents;
g) stolen goods, including digital goods;
h) illegal gambling or unlicensed lottery activity;
i) illegal weapons, firearms or ammunition;
j) intellectual property infringement activity;
k) prostitution or unlawful escort activity;
l) knowingly fraudulent business models;
m) unlawful forex or unlicensed financial services activity;
n) unlawful or unregulated crypto activity where licensing, registration, approval or authorisation is required; and
o) any activity that violates applicable law, regulation or sanctions restrictions.
9.3 The Company may from time to time maintain a list of prohibited or restricted industries, jurisdictions and use cases, and reserves the right to amend such list without notice.
10. SANCTIONS
10.1 The Company prohibits transactions, customer relationships and business relationships that would breach applicable sanctions laws or internal sanctions controls.
10.2 Accordingly, the Company may screen customers, beneficial owners, directors, authorised persons, counterparties, wallets, transactions and related parties against relevant sanctions lists and other screening sources applicable to the jurisdictions in which the relevant service entity and/or partner operates.
10.3 The Company has no risk appetite for establishing or maintaining a customer or counterparty relationship with any natural person or legal entity designated on an applicable sanctions list or otherwise prohibited by law or regulation.
10.4 Relevant sanctions screening sources may include, as applicable:
a) sanctions lists administered by the United States Office of Foreign Assets Control (“OFAC”);
b) sanctions lists and measures applicable in Canada;
c) United Nations sanctions lists;
d) European Union sanctions lists;
e) other national or international sanctions lists applicable to the relevant entity, partner, transaction flow or service; and
f) internal or partner-based sanctions controls and risk filters.
10.5 The Company may also pay particular attention to jurisdictions identified as high-risk, non-cooperative or otherwise subject to enhanced scrutiny by FATF, competent authorities, banking partners or compliance providers.
10.6 Where necessary, the Company may block, reject, suspend, freeze, review or report relevant transactions or relationships.
11. HIGH-RISK JURISDICTIONS
11.1 The Company may restrict, prohibit or apply enhanced due diligence to customers, counterparties, payment flows or activities involving jurisdictions considered high-risk from an AML, sanctions, fraud, corruption or financial crime perspective.
11.2 This may include jurisdictions:
a) identified by FATF as high-risk or under increased monitoring;
b) subject to sanctions or trade restrictions;
c) associated with heightened corruption, organised crime or terrorism financing risk;
d) associated with weak AML/CTF supervision or significant beneficial ownership opacity; or
e) identified as unacceptable by banking partners, payment partners or compliance providers.
11.3 The Company reserves the right to reject or terminate business involving such jurisdictions at any time.
12. POLITICALLY EXPOSED PERSONS (“PEPs”)
12.1 The Company may identify and assess whether a customer, beneficial owner, authorised person or close associate is a politically exposed person, family member of a politically exposed person or close associate of a politically exposed person.
12.2 Where a PEP relationship is identified, the Company may apply enhanced due diligence measures, including additional source of wealth and source of funds checks, management approval, increased monitoring and periodic review.
12.3 PEP status does not automatically prohibit a relationship, but it may result in additional scrutiny or rejection depending on the overall risk profile.
13. MONITORING FOR SUSPICIOUS ACTIVITY
13.1 The Company’s AML and CTF framework includes both onboarding controls and ongoing monitoring.
13.2 At various points in time, the Company may request further information regarding activity carried out through the customer’s account, wallet, payment flow, digital asset flow or related platform usage, including information about counterparties, commercial rationale, invoices, supporting contracts, source of funds, destination of funds or expected transaction behaviour.
13.3 If the customer fails to respond sufficiently, accurately or within a reasonable time, the Company may restrict, reject, return, delay, suspend or terminate the relevant activity or relationship, subject to applicable law.
13.4 Monitoring may include manual review, automated monitoring, behavioural analysis, sanctions screening, blockchain analytics, transaction pattern analysis, risk scoring and partner escalations.
13.5 Where suspicious activity is identified, the matter may be escalated internally and, where required, reported to the appropriate authority or partner.
13.6 The Company is not required to disclose to the customer whether a suspicious activity report, internal escalation or regulatory notification has been made.
14. SOURCE OF FUNDS / SOURCE OF WEALTH
14.1 The Company may require customers to provide evidence of source of funds and, where appropriate, source of wealth.
14.2 Such evidence may be requested at onboarding, before or after a transaction, periodically during the relationship, or upon trigger events such as unusual volume, unusual transaction patterns, exposure to high-risk jurisdictions, adverse media, PEP flags, crypto exposure or inconsistencies in the customer profile.
14.3 Failure to provide sufficient source of funds or source of wealth evidence may result in refusal, suspension, restriction or termination of the relationship.
15. SUSPICIOUS ACTIVITY REPORTING
15.1 The Company maintains internal procedures for the identification, escalation and handling of suspicious activity.
15.2 Relevant personnel are required to escalate concerns promptly through internal reporting channels. Where required by applicable law or by the relevant compliance structure, suspicious activity may be reported to the competent authority, regulator, financial intelligence unit, banking partner or other authorised party.
15.3 The Company may delay, block, reject or freeze activity while a suspicious matter is under review, subject to applicable law.
16. EMPLOYEES’ OBLIGATIONS
16.1 Relevant employees, officers, contractors and compliance personnel must comply with applicable AML/CTF laws, internal policies and escalation procedures.
16.2 They must, without undue delay, report any known or suspected money laundering, terrorist financing, sanctions evasion, fraud or related financial crime concerns through the appropriate internal channels.
16.3 Failure to comply with such obligations may result in disciplinary action, contractual consequences and, where applicable, legal or regulatory consequences.
16.4 The Company expects relevant personnel to cooperate fully with internal investigations, compliance reviews, partner requests and lawful regulatory inquiries.
17. RECORDKEEPING
17.1 The Company maintains records relating to customer identification, verification, beneficial ownership, transactions, monitoring, reviews, communications, escalations and compliance decisions for the period required by applicable law, regulation, audit standards, partner requirements or internal policy.
17.2 Such records may be maintained in electronic form and may be shared with relevant service providers, partners, authorities or auditors where legally permitted or required.
18. TRAINING AND AWARENESS
18.1 The Company provides AML/CTF-related training, guidance and awareness measures to relevant personnel as appropriate to their role and risk exposure.
18.2 Training may cover topics including:
a) AML/CTF fundamentals;
b) sanctions compliance;
c) customer due diligence and enhanced due diligence;
d) suspicious activity indicators;
e) internal escalation procedures;
f) fraud risks;
g) data handling and confidentiality; and
h) regulatory or policy changes.
18.3 Training frequency and format may vary depending on role, seniority and business function.
19. USE OF THIRD-PARTY COMPLIANCE PROVIDERS
19.1 The Company may use third-party compliance, onboarding, KYC, KYB, sanctions screening, identity verification, fraud prevention, adverse media and blockchain analytics providers in support of its AML/CTF framework.
19.2 The use of such providers does not limit the Company’s discretion to request additional information, apply additional controls or decline business that it considers unacceptable from a compliance or risk standpoint.
20. RIGHT TO REJECT, RESTRICT OR TERMINATE
20.1 The Company reserves the right, at its sole discretion and subject to applicable law, to:
a) reject any customer application;
b) request additional information or documentation;
c) delay, suspend or reject a transaction;
d) impose account, wallet or payment restrictions;
e) freeze or limit activity pending review;
f) offboard or terminate a relationship; and/or
g) refuse any product, jurisdiction, counterparty or business model,
where doing so is considered necessary or appropriate from an AML, CTF, sanctions, fraud, legal, regulatory, operational or reputational risk perspective.
21. NO RELIANCE BY CUSTOMER
21.1 This AML and CTF Policy is intended to describe the Company’s compliance approach and controls. It does not create any obligation to provide services to any person, nor does it limit the Company’s right to apply stricter standards, additional controls or revised requirements at any time.
21.2 Nothing in this Policy shall be interpreted as a guarantee that any applicant, customer, transaction or business activity will be approved.
22. CHANGES TO THIS POLICY
22.1 The Company reserves the right to amend, replace, update or supplement this AML and CTF Policy at any time.
22.2 The latest version will be made available on the website or platform where appropriate. Continued use of the Site or Services after any update may constitute acceptance of the updated version, to the extent permitted by law.
23. CONTACT
23.1 If you have questions regarding AML/CTF matters, onboarding requirements, compliance reviews or related issues, you should contact the support or compliance channel made available through the Valens Pay platform or website.
24. VERSION
24.1 Version date: April 2026.