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AML / CFT Policy (Anti-Money Laundering & Counter-Terrorist Financing)

Last Updated: November 20, 2025

NEXA PAYMENTS INC. (operating as YOB Pay) is committed to preventing its platform from being used for money laundering, terrorist financing, or any form of illicit financial activity. This AML/CFT Policy establishes the framework and controls used to ensure robust compliance with applicable regulations and industry standards.

Policy Purpose

The purpose of this policy is to ensure that NEXA PAYMENTS INC. (YOB Pay) operates in full compliance with AML/CFT laws, maintains strong internal safeguards, and actively identifies, mitigates, and reports risks associated with illicit financial activities. It protects the company, its clients, and the financial system by establishing clear procedures, responsibilities, and controls.

1. KYC / KYB Processes

Individual Clients (KYC)

  • Collection and verification of identity documents (passport, national ID, driver’s license).
  • Verification of personal details: full name, date of birth, address, nationality.
  • Source of funds verification where required.
  • Enhanced due diligence for higher-risk individuals.
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Corporate Clients (KYB)

  • Verification of company registration documents.
  • Identification and verification of directors and UBOs.
  • Assessment of business activity and ownership structure.
  • Enhanced due diligence – Nexa Pay requesting additional supporting documents for corporate clients like: Recent balance sheet, proof of company address, recent invoices or contracts to verify the operational and financial profile

2. Risk Scoring

  • Clients are assigned risk levels (low/medium/high) based on jurisdiction, industry, transaction behaviour, and onboarding information.
  • Higher-risk clients undergo enhanced checks and more frequent reviews.

3. Transaction Monitoring

  • Continuous monitoring for unusual or inconsistent patterns.
  • Automated alerts for threshold breaches and known risk typologies.
  • Manual review and escalation by the compliance team when needed.

4. Red Flags & Suspicious Activity Reporting (SAR)

  • Identification of potential ML/TF indicators such as inconsistent behaviour, high-risk jurisdictions, or abnormal transaction patterns.
  • Investigation of flagged transactions.
  • Filing of SARs with FINTRAC when suspicion is confirmed.

5. PEP & Sanctions Screening

  • Screening at onboarding and on an ongoing basis.
  • Checks against PEP lists, sanctions list (UN, OFAC, EU, UK HMT), and other restricted entities.
  • Enhanced due diligence for any positive match.

6. Internal Controls

  • Segregation of duties and clear compliance oversight.
  • Regular audits, system testing, and staff training.
  • Use of secure technology for monitoring, screening, and maintaining records.