1. Introduction

The Anti-Money Laundering and Know Your Customer Policy (hereinafter referred to as "AML/KYC Policy") aims to prevent and reduce the potential risks of KuPay being involved in any illegal activities.

2. Purpose

KuPay follows practices and measures in the field of Anti-Money Laundering (AML) and Counter-Terrorism Financing. These measures are intended to demonstrate that KuPay takes seriously any attempt to use its services for illegal purposes.

3. Important Notice

KuPay warns users against attempting to use KuPay for money laundering, terrorist financing, any fraud, and purchasing prohibited goods and services. KuPay, its management, employees, and domain owners are not responsible for third-party abuse of services, intruder actions, and possible losses associated with using KuPay.

4. Requirements

To prevent illegal transactions, KuPay has set certain requirements for all applications created by users:

1. The payment sender and receiver in the application must be the same person. Using the service to transfer to third parties is strictly prohibited.

2. All contact information entered by users in applications, as well as other personal data transmitted to the service, must be up-to-date and completely reliable.

3. Users are prohibited from creating applications using anonymous proxy servers, VPNs, Tor, or any other anonymous internet connections.

5. Verification Procedures

One of the international standards for preventing illegal activities is Customer Due Diligence (hereinafter referred to as "verification"). For this purpose, KuPay implements its own verification procedures in terms of strict anti-money laundering and know-your-customer programs.

I. KuPay may require users to provide reliable, independent source documents, data, or information to verify and confirm the source of funds. This may include:

1. Passport photo in an unfolded form, with photo and full name clearly visible;

2. Passport scan or photo (good quality of first page, second page, and registration page);

3. Confirmation of fund source (photos, screenshots, extracts);

4. In the video, the person sending funds holds an unfolded passport (photo and full name clearly visible), stating that they created an application ID at KuPay's exchange (application number), the sent funds are their personal funds, they take full legal responsibility for this cryptocurrency, and they need to mention the source of funds in the video;

5. A recorded video of sending funds from the platform, where we should see the hash, sender and recipient addresses, amount with marking symbols, and transaction date. The video must be at least 10 seconds long;

II. If blocked due to high risk or official investigation, funds will be held until verification is completed or investigation is finished. For this, KuPay reserves the right to collect user identity information to comply with AML/KYC policy.

III. KuPay will take measures to verify the authenticity of documents and information provided by users. All legal methods will be used for double verification of identity information, and reserves the right to investigate cases of certain users who have been identified as dangerous or suspicious identities.

IV. The service reserves the right to continuous verification of users' identities, especially when their identity information has changed or their activity appears suspicious (unusual for specific users). Additionally, the service reserves the right to request updated documents from users even if they have been previously verified.

V. User identity information will be strictly collected, stored, shared, and protected according to KuPay's privacy policy and related rules.

VI. After confirming user identity, KuPay may refuse to provide services to users if KuPay's services are used for illegal activities.

VII. Users intending to use card consumption services must pass card verification according to instructions provided on KuPay's website.

VIII. KuPay has regulatory requirements to verify the source of funds or cryptocurrency to know if the source of funds used by users for transactions is legal.

6. Responsible Officer

The person responsible for AML compliance is KuPay's legal authorized person, whose duty is to ensure effective implementation and enforcement of AML/KYC policy.

1. This officer's duties are to control all aspects of KuPay's anti-money laundering activities, including money laundering and terrorist financing, including but not limited to the following methods: collecting user identity information; creating and updating internal policies and procedures to complete, review, submit and store all reports and records required by applicable laws and regulations; monitoring transactions and investigating any significant deviations; implementing a record management system to properly store and retrieve documents, folders, forms and logs; regularly updating risk assessments; providing required information to law enforcement agencies according to applicable laws and regulations.

2. The AML Compliance Officer has the authority to interact with law enforcement agencies involved in preventing money laundering, terrorist financing, and other illegal activities.

7. System Functions

KuPay performs many compliance tasks, including data collection, filtering, record keeping, investigation management, and reporting. System functions include:

1. Daily checking of users against recognized blacklists (e.g., OFAC), aggregating transfers to multiple data points, placing users on watch lists and service denial lists as applicable, opening investigation cases when appropriate, sending internal communications and completing mandatory reports; case and document management.

8. Behavioral Analysis

KuPay verifies users not only by verifying their identity but more importantly by analyzing their transaction behavior. Therefore, KuPay relies on data analysis as a risk assessment and suspicion detection tool.

9. Risk Assessment

According to international requirements, KuPay adopts risk assessment practices to combat money laundering and terrorist financing. By applying risk assessment practices to combat money laundering, KuPay ensures that measures to prevent or reduce money laundering and terrorist financing are proportionate to the identified risks.

10. Customer Inspection

If KuPay management has reasonable suspicion that a user is attempting to use the service for money laundering or any other illegal operations, management has the right to:

1. Suspend user's transaction operations;

2. Request identity documents from users;

3. Request any additional information and documents from users when they conduct suspicious transactions;

4. Through the AML Compliance Officer, ensure that reports of suspicious transactions are forwarded to appropriate law enforcement authorities;

11. Privacy

KuPay guarantees client confidentiality according to the service's privacy policy.

1. KuPay and its employees commit to maintaining the confidentiality of facts related to any suspicious transactions. This obligation also applies to service users and third parties to whom transaction information is transferred;

2. The confidentiality obligation undertaken by KuPay employees remains effective after they leave their position or terminate any other contractual relationship with KuPay and when these employees are transferred to another workplace. According to legal provisions, disclosure of such information to government, law enforcement agencies, and other entities in specific circumstances does not constitute a breach of confidentiality;

3. The confidentiality obligation does not apply to information disclosure between financial institutions cooperating with KuPay that form a consolidated group, in cases where providing information is limited to legitimate use in preventing money laundering and financing terrorism;

12. Conclusion

Based on the above reasons, KuPay does not assume any legal responsibility for its use in money laundering, financing terrorism, or purchasing prohibited goods and services, but commits to taking all possible and feasible measures to prevent attempts to use KuPay for money laundering, financing terrorism, or purchasing prohibited goods and services.

By conducting transactions on KuPay, users agree to the terms of all these policies and commit to complying with these terms.