Internal AML Policy

1. Policy Purpose

2. New Payment System LLC (hereafter – “Fastoo”, or “provider”) represents a payment service provider subject to the laws of Georgia and the supervision of the National Bank of Georgia

3. Fastoo ensures compliance with regulatory legal requirements

4. The management of the company realizes that the prevention of money laundering, funding of terrorism and financial crime is a global issue that can be combated by close coordination between the private sector (market participants) and state structures

5. Fastoo is committed to ensure, based on the relevant regulatory requirements and international best practices, the existence of business processes and internal policies/procedures that allow it not only to avoid threats in the financial sector, also to offer customers a safe service environment and relevant products/services

6. It is important for Fastoo to have such mechanisms and processes within the company that will allow to deal with the current or future challenges in the financial environment

7. Fastoo recognizes that a safe environment for customers is crucial when providing services, at what point it is important for the company to implement appropriate preventive measures, which in addition to financial risk, also insures reputational risks

8. Fastoo aims to uphold the high standards established in the fight against money laundering and funding of terrorism, to ensure a high degree of compliance with the local legislative / regulatory requirements and to establish the best international practices at the local market

9. The present policy is based on the Law of Georgia 'about Promotion of Money Laundering and Funding of Terrorism Prevention', normative acts, recommendations and other binding rules issued by the National Bank of Georgia and the Financial Monitoring Service of Georgia related to the activities of the payment service provider.

2. Money Laundering and Funding of Terrorism

1. According to the legislation of Georgia, money laundering is the legalization of illegal income, thus giving legal form to illegal and/or undocumented property (use of property, purchase, possession, conversion, transfer or other action) to cover its illegal and/or undocumented origin and/or other in order to assist a person to avoid the liability, concealing or masking its true nature, source of origin, location, placement, movement, ownership and/or other related rights as well;

2. Illegal property is a property, also income from this property, shares, which a person, a member of his family, a close relative or a related person has obtained in violation of the requirements of the law

3. Undocumented property is considered to be a property, also income from this property, shares (share), the person, a member of his family, a close relative or a related person does not have the documents confirming the acquisition by legal means, or it was obtained with the funds obtained as a result of the alienation of illegal property

4. Funding is the collection or delivery of financial funds or other property with the prior knowledge that they will be used or may be used by a terrorist or a terrorist organization and/or to implement terrorist activities, in whole or in part. Providing services, providing resources or other material support to a terrorist or a terrorist organization with prior knowledge as well

5. The fight against money laundering and funding of terrorism cannot be done separately. In both cases, Fastoo takes special care with users to duly assess and mitigate the risks associated with ML/TF

6. In the fight against the funding of terrorism, Fastoo applies the same preventive measures as in the fight against money laundering in order to detect and prevent the facts of funding of terrorism. Including customer identification/verification, study, transaction monitoring

3. Compliance Control

1. Taking into account the nature and scope of its activities, Fastoo ensures that it implements an effective system for assessing and managing the risks of money laundering and funding of terrorism (hereinafter referred to as the compliance control system).

2. This includes, but is not limited to, Fastoo's implementation of such basic compliance control principles as:

   1.  Development and approval of internal instructions (AML policy) for the implementation of the compliance control system

   2.  Assessing the risks of money laundering and funding of terrorism related to the customer and assessing the risk level of customers in accordance with the legislation;

   3.  Implementation of preventive measures (Customer Due Diligence) in accordance with the legislation, including identification/verification of customers;

   4.  Verification of customers in lists of politically active, sanctioned persons provided by UN Security Council resolutions and sanctions regimes required by the National Bank in written instructions;

   5.  A system for detecting suspicious/unusual transactions, which is proportionate to the nature, volume and related money laundering and funding of terrorism risks of its activities;

   6.  Storage of information/documentation in the manner and period established by law

3. In order to fulfill the obligations listed above, Fastoo ensured the establishing of the structural unit - compliance direction.

4. The Compliance direction implements activities related to money laundering and the prevention of funding of terrorism, including the development of relevant policies/procedures, the implementation of tasks/activities related to the financial monitoring process, and the performance of activities provided by relevant regulatory requirements and international experience.

4. Preventive Measures

1. According to the information/documentation obtained as a result of the implementation of preventive measures (including taking into account the information about the products/services used by the customer):

   1. customer's risk profile is determined;

   2. the scope of an additional information to be obtained is established;

   3. the content/format of the documentation confirming the obtained/obtainable information;

   4. the type of implementation of current monitoring (intensity);

2. The implementation of preventive measures has influence on the decision of Fastoo to establish, continue or terminate the business relationship with the customer;

3. Fastoo implements the preventive measures taking into account the relevant circumstances in order to ensure the compliance of its activities with the legal requirements;

4. Implementation of the preventive measures includes:

   1. customer identification and verification based on a reliable and independent source

   2. Identifying the beneficial owner and taking reasonable steps to verify it based on a reliable source;

   3. determining the purpose and intended nature of the business relationship;

   4. monitoring of the business relations

5. When taking preventive measures against a legal entity, in addition to the above mentioned, Fastoo will also examine the ownership and control (management) structure of the customer;

6. When determining the purpose and intended nature of the business relationship, Fastoo determines the essence of the customer's activity, obtains information about the expected transactions nature volume and frequency;

7. When monitoring the business relationship, Fastoo will study the transactions prepared, entered into and/or executed by the customer to determine the extent to which it corresponds to the information known to it about the customer, the commercial or professional activities of the customer and the level of risk of the customer;

8. Fastoo updates the identification data obtained through the preventive measures and other information/documentation with the periodicity determined by the legislation and internal policy;

9. The implementation of the preventive measures is determined in accordance with the risk level of the customer in the following cases:

   1. before concluding a single transaction;

   2. before establishing a business relationship;

   3. in the course of a business relationship;

   4. in the event of a change in the essential circumstances related to the customer;

10. Fastoo provides the implementation of the following types of preventive measures:

    1. simplified preventive measures;

    2. standard preventive measures;

    3. enhanced preventive measures;

11. Implementation of the preventive measures to verify the customer and/or beneficial owner in the presence of lower ML/TF risks can be completed after the establishment of a business relationship, if this is needed to avoid the hinder of the services for the customer;

    1. In such a case, the implementation of the preventive measures is completed within the scope of reasonable possibility, within a period of no more than 30 calendar days. In addition, it is prohibited to perform operations on the account on behalf or order of the customer until appropriate preventive measures are implemented;

12. Fastoo is authorized to implement the preventive measures electronically, without direct contact with the customer.

5. KYC Standard

1. Know Your Customer standard represents a process defined by Fastoo, which includes an aggregate of identification, verification and other related procedures of customers (including business partners), including recording and storage of information/documentation obtained during identification/verification and periodic update procedures;

2. KYC process is an ongoing process of a continuous nature, the observance of which is mandatory, both when establishing a business relationship with the customer, and throughout the entire period of its course;

3. In accordance with the KYC process, Fastoo ensures that the following steps are in place:

   1. Primary identification of the customer/partner - including identification data/documentation acquisition, collection, questionnaire, registration, storage;

   2. Verification of information/data obtained during the identification process (including verification through the independent reliable sources) and relevant analysis;

   3. When establishing a business relationship, determining the purpose and intended nature of the business relationship of the customer, analyzing information and following up;

   4. Studying, analyzing and taking appropriate measures of the transactions performed by and/or for the benefit of the customer or business partner;

   5. periodic updating of identification information/documentation in accordance with legal requirements;

4. Fastoo provides the identification and verification of the customer, when establishing a business relationship and/or concluding a single transaction;

5. Customer identification and verification may also be implement not only when establishing a business relationship / concluding a single transaction, but also before the continuation / during the course of a business relationship if there is a reason to implement the relevant procedure (renewal of identification / verification), including, there may be a reasonable doubt in the accuracy of the customer identification data/documents, or there may be doubts about the veracity, mutual compatibility of the identification data/documentation, the term of the presented identification document has expired or/and the important data recorded in it has been changed, etc.;

6. Fastoo provides the customer identification and verification in accordance with the legislation in force in Georgia, in particular the Law of Georgia 'about the Promotion of Preventing Money Laundering and Funding of Terrorism', the requirements determined by the normative acts approved by the order of the head of the Financial Monitoring Service of Georgia, the recommendations issued by the regulatory and the internal policy;

7. Fastoo is authorized to request any information/documentation from the customer to ensure the existence of a sound, smooth and valid process of compliance control, including identification and verification. In addition, at its discretion, taking into account the specific environmental factors and process, determine and request any additional information/documentation that will be needed for the purpose of studying the customer, his activities and/or the transactions performed by him;

8. Fastoo ensures that customers/persons in business relationships are included in the lists of sanctioned persons provided by the legislation of Georgia, the relevant legal act/written instructions of the National Bank of Georgia, and the sanctions regimes, and the lists of politically active persons, which include (including beneficial owners of customers/business associates) verification;

9. Fastoo does not establish and/or terminate a business relationship and/or enter into a single transaction with a customer in the event:

   1. it is not possible to take appropriate preventive measures;

   2. the person is recorded in the list of sanctioned persons specified in Sub-paragraph 5.8;

   3. Fastoo is unable to be ensured in effective management of risks to the individual;

10. Updating of identification data is also implemented within the framework of a long-term business relationship according to the appropriate risk level assigned to it;

11. In order, to identification purposes, the user fills the KYC form defined by Fastoo.

6. Risk-Based Solution

1. The risk-based solution takes into account the legislative requirements of Georgia, the provisions of the Financial Monitoring Service of Georgia, the Financial Action Task Force (FATF) and other international recommendations;

2. A risk-based solution allows Fastoo to adequately assess its risks and the risks associated with its activities

3. Overestimation of risks causes to untargeted spending of resources, and improper estimation makes the company vulnerable to the threats it faces. Accordingly, the provider, using a risk-based solution, determines proportionate actions for the identified risks in order to reduce and control them

4. Leadership of Fastoo ensures the development of an effective and efficient compliance control system for risk management, including taking into account the size of the organization, the specificity of activities and ML/TF risks;

5. A risk-based solution includes the following issues:

   1. organizational risk assessment;

   2. establishing a complex vision;

   3. preventive measures (including KYC standard);

   4. monitoring and updating;

6. Risks identified and assessed by Fastoo (including organizational, customer and other) are subject to a periodic review at intervals determined by the respective risk level;

7. In addition, the revisions are also provided, when the actual circumstances change (including service/product changes, new services/products, new threats during originating and/or as a result of changes in legislative provisions).

7. Monitoring, Information recording and Control

1. Monitoring:

   1. Taking into account the legal requirements and international best practices, Fastoo monitors the performed/ to be performed transactions;

   2. Monitoring is carried out in accordance with a risk-based solution;

   3. During transactional monitoring, attention is paid to signs that may indicate money laundering;

   4. Fastoo acts in accordance with the legislation of Georgia in case of detection of suspicious/unusual transactions, which includes providing information to relevant authorities;

2. Information Recording:

   1. For the purposes of effectively managing the compliance control system, Fastoo ensures that customer information is recorded and stored electronically (materially if required);

   2. Fastoo also records additionally the data recorded in the process of preventive measures and relevant monitoring;

3. Control

   1. It is important for Fastoo that the team is manned by the qualified and reliable persons with a good reputation in order to ensure a high quality of service, and to reduce risks in various directions, including fraud, reputational, financial and others. Based on all of the above mentioned, Fastoo ensures the existence of the KYE process;

   2. One of the components of raising the culture of compliance is the consulting and training of employees regarding the issues of ML/TF;

   3. Fastoo provides educational/informational programs and trainings for the employees.