Anti-Money Laundering Policy

1. Introduction

Caibo Pay is committed to preventing money laundering, terrorist financing, and other financial crimes. As a registered Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), we maintain a comprehensive Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) compliance program.

This policy outlines our approach to detecting, preventing, and reporting suspicious financial activity in accordance with Canadian law and international best practices.

2. Regulatory Framework

Caibo Pay operates in full compliance with the following regulatory requirements:

• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) • Regulations issued by FINTRAC • Canadian Sanctions regulations under the United Nations Act, the Special Economic Measures Act, and the Justice for Victims of Corrupt Foreign Officials Act • Applicable provincial regulations in New Brunswick, Canada

We regularly review and update our compliance program to reflect changes in legislation, regulations, and guidance from FINTRAC and other regulatory bodies.

3. Customer Due Diligence (KYC)

We verify the identity of all customers before allowing transactions. Our Know Your Customer (KYC) program includes:

• Government-issued photo identification verification • Proof of address verification • Beneficial ownership identification for business accounts • Enhanced due diligence for higher-risk customers and transactions • Ongoing monitoring and periodic re-verification of customer information • Politically Exposed Persons (PEP) screening

We do not open accounts or process transactions for customers who fail to complete our verification requirements.

4. Transaction Monitoring

We monitor all transactions for suspicious activity using a combination of automated systems and manual review. Our monitoring program includes:

• Real-time transaction screening against known patterns of suspicious activity • Monitoring for unusual transaction patterns, volumes, or frequencies • Detection of structuring or attempts to avoid reporting thresholds • Cross-border transaction monitoring • Ongoing review of high-risk transactions and customer relationships

Transactions that trigger alerts are escalated for review by our compliance team.

5. Sanctions Screening

All customers, beneficiaries, and transactions are screened against applicable sanctions lists, including:

• Canadian Consolidated Autonomous Sanctions List • United Nations Security Council Consolidated List • Other applicable international watchlists and sanctions programs

Screening is performed at onboarding, at the time of each transaction, and on an ongoing basis as sanctions lists are updated. Positive matches result in the blocking of transactions and reporting to the relevant authorities.

6. Record Keeping

We maintain records of all customer identification information and transactions as required by the PCMLTFA. Records are retained for a minimum of five years from the date of the last transaction or the date the business relationship ends, whichever is later.

Our record-keeping practices ensure that information is available for audit, regulatory review, and law enforcement purposes as required.

7. Reporting Obligations

We comply with all mandatory reporting requirements under Canadian law, including:

• Suspicious Transaction Reports (STRs) filed with FINTRAC • Large Cash Transaction Reports (LCTRs) for transactions of $10,000 CAD or more • Electronic Funds Transfer Reports (EFTRs) for international transfers of $10,000 CAD or more • Terrorist Property Reports as required

All reports are filed within the timelines prescribed by FINTRAC regulations.

8. Employee Training

All employees receive AML/ATF compliance training upon hiring and on an ongoing basis. Training covers:

• Recognition of suspicious transactions and activities • KYC procedures and customer due diligence requirements • Reporting obligations and internal escalation procedures • Updates to relevant laws, regulations, and company policies

Our compliance officer is responsible for overseeing the training program and ensuring all staff maintain current knowledge of AML/ATF requirements.

9. Compliance Officer

Caibo Pay has appointed a Chief Compliance Officer responsible for:

• Overseeing the implementation and effectiveness of the AML/ATF compliance program • Ensuring compliance with all applicable laws and regulations • Managing relationships with FINTRAC and other regulatory bodies • Reviewing and approving suspicious transaction reports • Conducting periodic risk assessments and program reviews

10. Contact

For compliance-related inquiries, please contact our compliance team:

Email: compliance@caibopay.com

Caibo Inc. Moncton, New Brunswick, Canada

We take all compliance inquiries seriously and will respond in a timely manner.