Know Your Customer (KYC) & Anti-Money Laundering (AML) Policy

1. Introduction and Purpose

1.1 Policy Statement

Caribbean Payments Alliance ("CPA"), operating under Sebastian Alliance Group (SAG), is committed to maintaining the highest standards of regulatory compliance and financial integrity. This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy establishes the framework for customer identification, verification, and ongoing monitoring to prevent financial crimes including money laundering, terrorist financing, and fraud.

1.2 Scope

This policy applies to:

• All QuickPay Solutions account holders
• Merchant accounts and business users
• Sub-wallet operators
• SAG Debit Card applicants
• All employees, contractors, and third-party service providers

1.3 Regulatory Framework

This policy is designed to comply with:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Financial Action Task Force (FATF) Recommendations
• Office of Foreign Assets Control (OFAC) Regulations
• Applicable Caribbean jurisdiction regulations

2. Customer Identification Program (CIP)

2.1 Individual Customers

Required Information:

Required Documents:

1. Government-Issued Photo ID (one of the following):
   • Valid Passport
   • Driver's License
   • National Identity Card
2. Proof of Address (dated within 3 months):
   • Utility bill (electricity, water, gas)
   • Bank statement
   • Government correspondence
   • Lease agreement
3. Selfie Verification:
   • Live photo holding government ID
   • Face must be clearly visible

2.2 Business Customers

Required Documents:

1. Business Registration Certificate
2. Tax Identification Number (TIN/EIN)
3. Proof of Business Address
4. Beneficial Owner Identification (for each owner ≥25%)
5. Bank Account Verification (for fund settlements)

3. Customer Due Diligence (CDD)

3.1 Risk-Based Approach

3.2 Enhanced Due Diligence (EDD)

Required for high-risk customers and includes:

• Source of funds verification
• Source of wealth documentation
• Senior management approval for onboarding
• More frequent transaction monitoring
• Additional reference checks

4. Verification Process

4.1 Verification Workflow

4.2 Verification Timeframes

• Standard Verification: 24-48 business hours
• Enhanced Due Diligence: 5-7 business days
• Annual Re-verification: Required every 12 months

5. Sanctions and PEP Screening

All customers are screened against:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated Sanctions List
• Politically Exposed Persons (PEP) databases
• Negative news/adverse media

5.1 Screening Frequency

• Onboarding: 100% of new customers
• Ongoing: Daily batch screening of customer database
• Transaction-Based: Real-time screening for high-value transactions

6. Transaction Monitoring

6.1 Monitoring Parameters

The following transaction patterns trigger review:

• Single transactions exceeding $10,000
• Cumulative daily transactions exceeding $25,000
• Unusual transaction frequency or patterns
• Transactions to/from high-risk jurisdictions
• Sudden changes in transaction behavior

6.2 Red Flags

• Structuring (breaking transactions to avoid thresholds)
• Rapid movement of funds
• Transactions inconsistent with stated business purpose
• Multiple failed transaction attempts
• Use of multiple accounts/devices

7. Record Keeping

8. Contact Information