PayTres.com, operated by Moomoth Global Limited, UK (Company Number: 13782526), with its registered office at 6 Crown Road, Orpington, England, BR6 6JN, is committed to adhering to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy aims to prevent the misuse of our platform for unlawful activities, including money laundering, terrorism financing, and other financial crimes.

This AML and CTF Policy establishes a robust framework to identify, detect, mitigate, and address risks associated with financial crimes. This policy applies to all employees, officers, directors, third-party vendors, customers, users, and all other associated persons or entities.

By accessing and using PayTres.com, you agree to comply with this AML Policy, along with our Terms of Service and Privacy Policy. If you do not agree with these policies, you may not access or use our services.

1. Principles

We are committed to the following principles:

• Ensuring all operations comply with applicable laws and regulations, including those in the UK, EU, and India.
• Conducting regular risk assessments to understand and mitigate money laundering and terrorist financing risks.
• Implementing and monitoring effective AML procedures.
• Preventing the misuse of PayTres.com for illicit activities, including money laundering and terrorist financing.
• Cooperating fully with relevant law enforcement agencies and authorities.

2. Users' Obligations

• Users must not use the platform in any way that contravenes this AML Policy, the Terms of Service, the Privacy Policy, or any applicable laws.
• Users must provide true, accurate, and complete information during the registration and verification process.
• Any changes to personal details, such as address, must be updated within 3 (Three) months.
• Users must not engage in suspicious transactions or interact with persons or entities on sanctions lists issued by competent authorities such as OFAC, the EU, or the UN.
• PayTres.com reserves the right to block, restrict, or terminate accounts suspected of engaging in illegal activities.

3. Customer Due Diligence (CDD)

3.1 KYC (Know Your Customer)

To mitigate risks, all users must complete a KYC verification process, including providing government-issued identification and other valid documents.

3.2 KYC Tiers

• Basic KYC: Required for all users and includes phone number verification and identity document submission.
• Full KYC: Required for users exceeding specific transaction thresholds, including video verification and proof of funds.

KYC is mandatory at the time of onboarding and may be requested at any time during a user's interaction with the platform.

Submitted identity documents must be in English or accompanied by certified translations.

3.5 Additional Information on KYC Process

The Know Your Customer (KYC) process on PayTres.com may be conducted directly by Moomoth Global Limited, the operating entity for PayTres.com, or through its authorized partners or associates.

By using the platform, users acknowledge and agree that the personal information provided during the KYC process may be shared with:

• Regulatory Authorities: Regulatory bodies and their representatives for compliance purposes.
• Government Agencies: Government bodies in specific regions or countries as mandated by law.
• Other Competent Authorities: Agencies or organizations required to ensure adherence to anti-money laundering, counter-terrorist financing, and other related regulations.

This sharing of information is critical to ensuring compliance with applicable laws and preventing misuse of the platform for illegal activities. Users consent to this disclosure as a condition of using PayTres.com.

PayTres.com reserves the right to update this policy periodically in accordance with evolving regulatory guidelines, government directives, or operational requirements. Updates will reflect changes in relevant laws, regulations, and best practices to ensure compliance and safeguard the interests of PayTres.com and its users.

We encourage users to review this policy regularly to stay informed of any changes. Notifications about significant updates will be provided on the PayTres.com website or through other communication channels as deemed appropriate by the company.

4. Enhanced Due Diligence (EDD)

EDD is applied to high-risk customers, such as Politically Exposed Persons (PEPs) or users from high-risk jurisdictions. This includes:

• Frequent transaction reviews.
• Collection of additional information.
• Conducting independent verification of user details.
• Monitoring transactions for unusual patterns.

Transactions with individuals or entities on prescribed sanctions lists are prohibited. Any suspicious activity will be reported to the relevant authorities.

In the case of foreign PEPs, we ensure additional safeguards, including senior management approval, verification of the source of funds, and enhanced monitoring.

5. Monitoring Transactions

• All transactions are monitored for suspicious activity based on the user's risk profile. Suspicious transactions will be flagged for investigation.
• We reserve the right to request additional information from users to verify the legitimacy of transactions.
• Any suspected cases of money laundering or terrorist financing will be reported to the appropriate law enforcement authorities.

6. Risk Assessment

We employ a risk-based approach to categorize users into low, medium, and high-risk profiles. Factors include:

• The sufficiency of identification information.
• Geographical location.
• Complexity or value of transactions.
• Association with high-risk jurisdictions.

7. Record Keeping

• All user information collected during the CDD and EDD processes is securely stored as per applicable laws, including GDPR and Indian data protection regulations.
• Records are retained for at least five years or as mandated by law.

8. Employee Training and Awareness

All employees undergo regular training on AML compliance, enabling them to identify suspicious activity and fulfill their AML responsibilities effectively.

9. Compliance and Enforcement

9.1 Compliance Officer

Our Compliance Officer oversees the implementation of this AML Policy. Contact details:

• Title: Compliance Officer
• Address: 6 Crown Road, Orpington, England, BR6 6JN
• Email: [email protected]

Users are encouraged to report suspicious activities or transactions to the Compliance Officer.

10. Policy Review

• This AML Policy is reviewed annually or as required by changes in regulations or operations. Updates will be published on PayTres.com, and stakeholders are advised to review the policy periodically.
• While this policy provides a robust framework, it does not guarantee the complete prevention of money laundering or terrorist financing. Continuous improvements to systems and procedures are a priority.