Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy Summary

1. Our Approach

ThirdPay is a U.S.-incorporated company offering self-custodial digital wallets for businesses and individuals. While we do not hold custody of fiat funds or digital assets, we have implemented policies, procedures, and controls to mitigate financial crime risks associated with our platform.

We maintain an internal AML/CTF program consistent with industry standards and appropriate to our risk profile.

Regulatory Status

ThirdPay is not a licensed money services business (MSB), money transmitter, bank, broker-dealer, or investment adviser under U.S. law or the laws of any other jurisdiction. ThirdPay provides self-custodial wallet services and limited concierge support, but does not hold or custody fiat funds or digital assets on behalf of users.

2. Know Your Business (KYB) Procedures

We perform Know Your Business (KYB) onboarding for all business users prior to account activation. KYB reviews include:

• Verification of legal entity existence and good standing
• Collection of incorporation documents, ownership structure, and management information
• Identification and verification of shareholders and directors with 25% or greater ownership
• Screening of individuals and entities against government-issued sanctions lists (e.g., OFAC, EU, UN, UK)
• Assessment of the nature and purpose of the business relationship

Third-Party Identity Verification

For certain services, including payment acceptance and on-/off-ramp transactions, ThirdPay’s third-party providers may conduct Know Your Customer (KYC) or Know Your Business (KYB) checks directly with users.

These providers operate under their own compliance programs and are responsible for independently verifying the identities of users where applicable.

ThirdPay may rely on the results of third-party verification processes but does not control or guarantee the outcome of such checks.

3. Sanctions Compliance

ThirdPay does not support accounts for individuals, businesses, or jurisdictions subject to comprehensive economic sanctions administered by the United States Office of Foreign Assets Control (OFAC), United Nations, European Union, or United Kingdom.

We geo-block access to the Services from sanctioned jurisdictions and continuously monitor regulatory updates to maintain compliance.

4. Monitoring and Ongoing Due Diligence

ThirdPay conducts periodic reviews of Business Accounts based on risk factors, including:

• Material changes in the ownership structure or operations of the business
• Transaction patterns inconsistent with stated business purpose
• Adverse media or regulatory actions

We reserve the right to request updated information and supporting documents from users as part of our ongoing compliance obligations.

5. Reporting Suspicious Activity

ThirdPay monitors user activity for indications of potential money laundering, terrorist financing, or sanctions evasion. Where appropriate and as required by law, ThirdPay will report suspicious activities to the relevant authorities.

6. Training and Awareness

ThirdPay’s employees and key contractors receive training on AML/CTF policies, regulatory obligations, and red flags associated with financial crime risks.

7. No Customer Custody

As a reminder, ThirdPay does not custody user fiat funds or private keys. Users are responsible for their own wallet security and asset management.

8. Contact Us

For questions regarding our AML/CTF practices, please contact:

ThirdPay Innovations Inc.

8 The Green, STE A,

Dover, Delaware, DE 19901

United States of America

Email: hello@thirdpay.io