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

1. Introduction

PayBee Me (the "Company") is committed to preventing money laundering and terrorist financing (collectively, "AML/CFT") activities in accordance with applicable laws and regulations. This AML/KYC Policy outlines the procedures we implement to mitigate these risks.

2. Purpose

The Company adheres to AML/CFT best practices to deter and detect suspicious activity on the xChange platform (the "Platform"). This policy demonstrates our commitment to preventing the Platform's use for illegal purposes.

3. User Conduct

Users are prohibited from using the Platform for:

• Money laundering
• Terrorist financing
• Fraud
• Purchasing prohibited goods or services

The Company will not be held liable for misuse by third parties.

4. User Requirements

To prevent illegal transactions, the Platform sets forth certain requirements for user applications:

• Transaction Parties: The sender and recipient of a transaction must be the same user. Third-party transfers are prohibited.
• Accurate Information: All user-provided information must be current and accurate.
• Prohibited Connections: Creating applications using anonymous connections (proxies, VPNs, Tor) is strictly forbidden.

5. Verification Procedures

The Company implements KYC verification procedures to comply with AML/CFT regulations. These procedures may require users to provide:

• Government-issued identification (e.g., national ID, passport)
• Bank statements
• Other relevant documents

Verification can take up to seven days, with potential extensions in complex cases. The Company reserves the right to:

• Verify document authenticity
• Investigate suspicious users
• Request updated documents
• Conduct ongoing identity verification

User identification information will be collected, stored, and protected in accordance with the Company's Privacy Policy.

The Company may refuse service if it suspects illegal activity. Users must complete card verification processes for card-based transactions. The Company also reserves the right to verify the source of user funds.

6. AML Compliance Officer

The Company designates an AML Compliance Officer to oversee the implementation and enforcement of this Policy. The Officer's responsibilities include:

• Monitoring user identification information
• Creating and updating internal AML/CFT policies and procedures
• Monitoring transactions and investigating suspicious activity
• Maintaining a records management system
• Updating risk assessments
• Reporting to law enforcement as required by law

The Officer may interact with law enforcement agencies regarding AML/CFT investigations.

7. System Functions

The Platform performs several compliance-related tasks, including:

• User screening against sanctioned lists
• Transaction monitoring for suspicious activity
• User watchlists and denial-of-service lists
• Investigative case management
• Regulatory reporting

8. Behavioral Analysis

The Company analyzes user transaction behavior to assess risk and detect suspicious activity.

9. Risk Assessments

The Company applies risk-based AML/CFT measures proportionate to the identified risks.

10. Customer Due Diligence (CDD)

If suspicious activity is suspected, the Company may:

• Suspend user exchange operations
• Request additional user identification and information
• Report suspicious activity to law enforcement

11. User Privacy

The Company protects user privacy in accordance with its Privacy Policy. This includes maintaining confidentiality of information related to questionable transactions. However, disclosure may be required to law enforcement or other authorized entities by law.

12. Disclaimer

The Company cannot be held legally responsible for the Platform's use in illegal activities but will take all reasonable steps to prevent such misuse.

13. User Agreement

By using the Platform, users agree to this Policy and its terms.