Anti-Money Laundering Policy

1. Purpose

PG Ecom is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy establishes the framework and procedures we follow to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

2. Know Your Customer (KYC)

All customers must complete our KYC verification process before accessing card issuing and payment services. This includes:

• •Individual Verification: Government-issued photo identification, proof of address, and date of birth verification.
• •Business Verification (KYB): Business registration documents, articles of incorporation, beneficial ownership disclosure, and proof of business address.
• •Enhanced Due Diligence: Additional verification for high-risk customers, politically exposed persons (PEPs), and businesses in higher-risk jurisdictions.

3. Transaction Monitoring

We maintain systems to monitor transactions for suspicious patterns, including unusual transaction volumes, rapid movement of funds, transactions inconsistent with customer profiles, and structuring activities designed to avoid reporting thresholds. Flagged transactions are reviewed by our compliance team.

4. Sanctions Screening

All customers and transactions are screened against international sanctions lists, including OFAC, EU sanctions lists, UN sanctions lists, and other applicable national and regional sanctions programs. Matches are escalated for immediate review and action.

5. Suspicious Activity Reporting

When suspicious activity is identified, PG Ecom files Suspicious Activity Reports (SARs) with the appropriate financial intelligence units as required by law. Employees are prohibited from disclosing the existence of a SAR to any person, including the subject of the report.

6. Record Keeping

We maintain records of all customer identification documents, transaction records, and compliance activities for the minimum period required by applicable regulations. These records are stored securely and made available to regulatory authorities upon lawful request.

7. Employee Training

All PG Ecom employees receive regular AML/CTF training appropriate to their roles. Training covers identification of suspicious activities, reporting obligations, sanctions compliance, and updates to relevant laws and regulations.

8. Compliance Officer

PG Ecom maintains a designated Compliance Officer responsible for overseeing the implementation of this AML policy, ensuring regulatory compliance, and serving as the primary point of contact for regulatory inquiries.

9. Contact

For questions about our AML compliance program, contact our Compliance team at compliance@pgecom.com.