AML & Financial Crime Policy

SwiftPay Technologies Group Ltd

UK Headquarters with Ireland Branch

Version 1.0 | Effective Date: 30 August 2026 | Review: At least annually

1. Legal Entity and Structure

SwiftPay Technologies Group Ltd is the principal UK entity and headquarters of the SwiftPay business. The company is registered in England and Wales under company number 16799917. SwiftPay also operates through an Ireland branch. The Irish branch legal name, registration number and address should be completed from the official Irish branch record.

2. Purpose

SwiftPay Technologies Group Ltd is committed to preventing its products and services from being used for money laundering, terrorist financing, fraud, sanctions evasion or other financial crime. This policy establishes a risk based framework for identifying, assessing, managing and monitoring financial crime risks.

3. Scope

This policy applies to the UK headquarters, the Ireland branch where applicable, directors and senior management, employees and contractors, customers and business customers, merchants, relevant third party providers, payment processing activities, virtual and physical card programmes and API integrations.

4. Risk Based Approach

SwiftPay assesses customer, product, geographic, distribution channel, transaction and third party risks. Factors may include customer type, business activity, ownership structure, expected transaction activity, source of funds, source of wealth where appropriate, PEP status, sanctions status, geographic exposure, payment methods, card activity, transaction value and frequency, and unusual activity.

5. Customer Due Diligence and KYC

SwiftPay applies appropriate Know Your Customer and Customer Due Diligence measures where required. Individuals may be asked for legal name, date of birth, address, nationality, identification, contact details and source of income or funds where required. Businesses may be asked for legal name, registration details, addresses, business activity, directors, beneficial owners, ownership structure, authorised representatives, expected activity and source of funds where required.

6. Beneficial Ownership

For corporate customers, SwiftPay takes reasonable steps to identify individuals who ultimately own or control the customer. Additional corporate and identification documents may be requested where necessary.

7. Enhanced Due Diligence

SwiftPay may apply enhanced due diligence to higher risk customers or situations. Measures may include additional identity verification, corporate documentation, source of funds or wealth verification, additional business information, increased monitoring and appropriate management or compliance approval.

8. PEP Screening

SwiftPay may screen customers and relevant beneficial owners for Politically Exposed Person status. Where required, SwiftPay may establish source of wealth and source of funds, apply enhanced monitoring and obtain appropriate approval.

9. Sanctions Screening

SwiftPay maintains appropriate controls designed to identify sanctions concerns. Potential matches may be investigated and may result in additional information requests, restrictions, suspension or escalation to compliance or a regulated partner.

10. Transaction Monitoring

SwiftPay applies risk based monitoring appropriate to its products and services. Monitoring may identify unusual transaction values or frequency, rapid movement of funds, unusual card activity, linked accounts or cards, activity inconsistent with customer expectations, higher risk geographic exposure, unusual payment patterns, potential fraud and sanctions concerns.

11. Suspicious Activity

SwiftPay maintains procedures for identifying, investigating and escalating potentially suspicious activity. Where appropriate and legally permitted, SwiftPay may restrict or suspend accounts, decline or restrict transactions, request information, escalate to compliance or a regulated partner, and make reports to the appropriate authority where legally required.

12. Fraud Prevention

AML controls operate alongside fraud prevention controls. Depending on the service and risk level, controls may include identity verification, device and behavioural analysis, transaction monitoring, velocity controls, payment risk analysis, card activity monitoring, account monitoring, automated alerts and manual investigation.

13. Customer Risk Classification

Customers may be classified as low, medium or high risk. Risk classifications may be reviewed when there is a material change in circumstances, unusual activity, new information, a sanctions or PEP alert, a change in ownership or a significant change in transaction behaviour.

14. Ongoing Monitoring

SwiftPay may conduct ongoing monitoring proportionate to customer risk, including review of customer information, business activity, ownership, transaction activity, sanctions status, PEP status and risk classification.

15. Record Keeping

SwiftPay maintains appropriate records relating to customer identification, verification, beneficial ownership, risk assessments, enhanced due diligence, transaction activity, screening results, compliance investigations, suspicious activity reviews, relevant correspondence and training. Records will be retained for the period required by applicable law and contractual obligations.

16. Third Party and Regulated Partners

SwiftPay may use or work with Regulated Third-Party Financial Service Providers for identity verification, KYC, sanctions and PEP screening, fraud detection, transaction monitoring, card issuing, payment processing, banking and account services. Where regulated partners perform specific regulated functions, SwiftPay will cooperate with those partners and provide information reasonably required for compliance. SwiftPay will not claim to hold a regulatory authorisation that it does not hold.

17. Compliance Responsibility

Overall responsibility for the AML framework rests with senior management. SwiftPay will designate an appropriate person responsible for AML and financial crime oversight where required. Where a Money Laundering Reporting Officer or nominated officer is legally required, SwiftPay will appoint an appropriately qualified individual.

18. Training

SwiftPay will provide appropriate AML and financial crime awareness training to personnel whose responsibilities require it.

19. Regulatory Compliance

SwiftPay will comply with applicable laws and regulatory requirements relevant to its actual activities and operating structure. The company will maintain appropriate authorisation, registration or regulated partner arrangements where required. Public regulatory statements will be limited to matters that can be substantiated.

20. AML Business Risk Assessment

SwiftPay will maintain an AML Business Risk Assessment covering customer, product, geographic, distribution, payment method, card programme, transaction, third party and technology or API risks. The assessment will be reviewed periodically and when material changes occur.

21. Policy Review

This policy will be reviewed at least annually and when there are material changes to legislation, regulatory expectations, products, markets, payment or card providers, business model or financial crime risks.