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

1. Purpose

SmartPayFX is committed to preventing its payment infrastructure, customer accounts and supported services from being used for money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion or other unlawful activity.

The purpose of this AML & KYC Policy is to establish a risk-based framework for identifying customers, understanding transactions, detecting unusual or suspicious behaviour, maintaining appropriate records and taking proportionate action where financial crime risks are identified.

2. Scope

This Policy applies, as relevant, to users accessing SmartPayFX services including:

• Deposits and withdrawals involving supported trading platforms.
• Transactions between Deriv USD wallets and supported local mobile money services.
• Payments involving supported platforms such as Deriv, Weltrade, HFM and Exness.
• Buying or selling supported digital currencies such as USDT and Bitcoin (BTC).
• Transfers and other payment-related services made available through SmartPayFX.
• Mobile money services including M-Pesa, Airtel Money, Mixx by Yas and Halopesa, where supported.

3. Legal & Regulatory Framework

SmartPayFX seeks to operate its compliance programme consistently with applicable laws and regulatory requirements in the jurisdictions in which it provides services.

In Tanzania, the relevant AML/CFT framework includes the Anti-Money Laundering Act, Cap. 423 R.E. 2023 and applicable regulations, amendments, directives and guidance issued by competent authorities, including the Financial Intelligence Unit (FIU), where legally applicable to SmartPayFX.

SmartPayFX may also take into consideration applicable counter-terrorist financing, proliferation financing, targeted financial sanctions, fraud prevention and other financial-crime requirements.

Where legal requirements impose higher standards than this Policy, the applicable legal requirements will take precedence.

5. Know Your Customer (KYC) & Customer Identification

SmartPayFX may require users to complete identity verification before accessing certain services, transaction limits or payment features.

5.1 Information We May Request

Depending on the customer and risk level, SmartPayFX may request information such as:

• Full legal name.
• Date of birth.
• Nationality or country of residence.
• Mobile phone number and email address.
• Residential or contact address.
• Government-issued identification details.
• A clear copy or image of an accepted identity document.
• A photograph, selfie or other identity-verification evidence where necessary.
• Mobile money account or payment account ownership information.
• Trading platform account details where required to process a transaction.
• Information regarding the purpose and expected nature of the account relationship.

5.2 Verification

SmartPayFX may verify information provided by a user against reliable and independent documents, data sources, payment-provider information or verification services, where lawful and available.

5.3 Accurate Information

Customers must provide truthful, accurate and current information. SmartPayFX may request updated documentation when previously supplied information becomes outdated, inconsistent, incomplete or unreliable.

5.4 Anonymous or False Accounts

SmartPayFX does not permit users to intentionally operate accounts under false, fictitious or misleading identities.

6. Enhanced Due Diligence (EDD)

Higher-risk customers, transactions or relationships may be subject to Enhanced Due Diligence. The measures applied will depend on the nature and level of risk.

Enhanced checks may include:

• Requesting additional identification documents.
• Obtaining further information about occupation, business or economic activity.
• Requesting evidence regarding the purpose of a transaction.
• Verifying the source of funds or, where appropriate, source of wealth.
• Performing additional payment-account ownership checks.
• Conducting additional sanctions, PEP or adverse-information screening where legally appropriate.
• Applying enhanced or ongoing transaction monitoring.
• Obtaining internal approval before processing or continuing higher-risk relationships.

7. Source of Funds & Source of Wealth

SmartPayFX may request information or evidence showing how funds involved in a transaction were obtained, particularly where a transaction is unusually large, inconsistent with a customer's known profile, complex, high-risk or otherwise requires additional verification.

Supporting evidence may include, where appropriate:

• Bank or mobile money statements.
• Salary or employment documentation.
• Business income records.
• Trading account records or statements.
• Evidence of sale of an asset or investment.
• Other reasonable evidence supporting the legitimate origin of funds.

SmartPayFX may delay, limit, reject or hold a transaction for review where adequate information cannot be obtained.

8. Politically Exposed Persons (PEPs), Sanctions & Restricted Parties

Where required or appropriate based on risk, SmartPayFX may screen customers, beneficial owners and transactions against applicable sanctions lists, politically exposed person information and other legally relevant restricted-party information.

A relationship involving a PEP is not automatically prohibited. However, it may be subject to enhanced review, additional approval, source-of-funds or source-of-wealth checks and increased monitoring where required.

SmartPayFX may reject, freeze, restrict or otherwise decline a transaction where required by applicable sanctions, court orders, regulatory directions or other binding legal obligations.

9. Transaction Monitoring

SmartPayFX may monitor customer transactions and account activity to identify behaviour that is unusual, inconsistent or potentially indicative of financial crime.

Examples of activity that may trigger additional review include:

• Transactions that are unusually large or frequent compared with a customer's normal activity.
• Repeated transactions designed to avoid verification or transaction limits.
• Rapid movement of funds without an apparent economic or legitimate purpose.
• Use of multiple accounts, identities, mobile money numbers or payment instruments without reasonable explanation.
• Transactions involving unexplained third parties.
• Inconsistent customer, payment, trading-account or wallet ownership information.
• Unusual digital-currency activity or wallet patterns.
• Transactions associated with jurisdictions, persons or activities presenting elevated financial-crime risk.
• Attempts to conceal the true sender, recipient, beneficial owner or purpose of a transaction.

A transaction matching any of these indicators is not automatically unlawful. SmartPayFX may conduct further review before determining what action, if any, is appropriate.

10. Suspicious Transactions & Activity

Where SmartPayFX identifies activity that appears suspicious, unlawful or inconsistent with a customer's known profile, it may conduct an internal review and take any action permitted or required by law.

Such action may include:

• Requesting additional information or documentation.
• Temporarily delaying or restricting a transaction while checks are completed.
• Declining a transaction or service request.
• Restricting or terminating an account relationship.
• Escalating the matter internally to responsible compliance personnel.
• Making a report or disclosure to the Financial Intelligence Unit or another competent authority where legally required.

SmartPayFX may be prohibited by law from informing a customer that a suspicious transaction report, regulatory disclosure or related investigation has been made or is being considered.

11. Prohibited Use of SmartPayFX

Customers must not use SmartPayFX to:

• Launder proceeds of crime or disguise the source, ownership, destination or control of unlawful funds.
• Finance terrorism or support terrorist organisations or activities.
• Facilitate proliferation financing or prohibited weapons-related activity.
• Commit fraud, identity theft, account takeover, deception or payment abuse.
• Use stolen, unauthorised or fraudulently obtained funds or payment instruments.
• Evade sanctions, court orders, regulatory restrictions or applicable laws.
• Conduct transactions on behalf of unidentified or undisclosed third parties where this is prohibited or inconsistent with SmartPayFX requirements.
• Provide false, forged, manipulated or misleading documents or transaction information.
• Structure transactions for the purpose of avoiding KYC, transaction monitoring, reporting or other compliance controls.
• Use SmartPayFX for any other unlawful purpose.

12. Third-Party Payments & Account Ownership

SmartPayFX may require the name or ownership of a payment account, mobile money wallet, trading account or digital wallet to correspond with the verified SmartPayFX user.

Transactions involving third parties may be restricted, rejected or subjected to additional verification unless SmartPayFX is satisfied that the transaction is legitimate and permitted under applicable rules.

Customers must not use another person's identity, payment account or financial account without lawful authority.

13. Digital Currency Transactions

Because SmartPayFX supports selected digital currencies such as USDT and Bitcoin (BTC), additional risk controls may be applied to digital-asset transactions.

SmartPayFX may, where appropriate:

• Request information about the source or destination of digital assets.
• Request wallet ownership or transaction evidence.
• Review blockchain transaction information using available tools or information sources.
• Decline transactions associated with suspected fraud, theft, sanctions exposure or unlawful activity.
• Apply additional verification to higher-risk digital-asset transactions.

Availability of any digital-currency service remains subject to applicable laws, service-provider requirements and SmartPayFX risk controls.

14. Transaction & Account Restrictions

SmartPayFX reserves the right, subject to applicable law and contractual obligations, to delay, reject, reverse where technically and legally possible, limit, suspend or investigate a transaction or account where:

• KYC or other required verification has not been completed.
• Information provided by the customer appears inaccurate, false or inconsistent.
• There is suspected fraud, money laundering, terrorist financing or other unlawful activity.
• A transaction may violate applicable law, sanctions or service-provider requirements.
• SmartPayFX receives a lawful request or instruction from a competent authority.
• Additional information is reasonably required to understand the transaction.
• Continuing the service would expose SmartPayFX, its users or partners to unacceptable legal, fraud or financial-crime risk.

15. Record Keeping

SmartPayFX may retain records required for compliance, fraud prevention, dispute resolution, audit and legal purposes. These may include customer identification information, verification records, account information, transaction records, correspondence and compliance-review information.

Records will be retained for the period required by applicable law and regulatory requirements. Where a specific statutory retention period applies to SmartPayFX, that period will take precedence over internal policy.

Records should be sufficient, where required, to reconstruct relevant transactions and respond to lawful requests from competent authorities.

16. Privacy & Protection of Customer Information

Personal information collected for AML, KYC, fraud prevention and transaction-processing purposes will be handled in accordance with applicable privacy and data-protection requirements and SmartPayFX's Privacy Policy.

SmartPayFX may disclose customer or transaction information to regulators, law-enforcement agencies, courts, financial intelligence authorities, payment providers or other authorised parties when legally required or where disclosure is lawfully necessary for compliance, fraud prevention or protection of the service.

17. Internal Controls, Governance & Training

SmartPayFX aims to maintain internal controls proportionate to the nature, scale and risk of its activities.

These controls may include:

• Documented AML/KYC procedures.
• Assignment of responsibility for compliance oversight.
• Risk assessments for customers, products, services and transaction channels.
• Internal escalation procedures for unusual or suspicious activity.
• Access controls and appropriate separation of operational responsibilities.
• Periodic review of AML/KYC controls.
• Relevant AML, fraud and compliance awareness training for personnel.

18. Cooperation with Authorities & Service Providers

SmartPayFX may cooperate with competent authorities and regulated payment or financial-service partners in accordance with applicable law and valid legal requests.

This may include responding to lawful requests for information, preserving transaction records, restricting transactions or accounts where legally required, and making regulatory reports where applicable.

19. Customer Responsibilities

By using SmartPayFX, customers are expected to:

• Provide accurate, complete and current information.
• Use only accounts, wallets and payment methods that they are legally authorised to use.
• Respond to legitimate verification or compliance requests within a reasonable period.
• Provide supporting documents where required for transaction review.
• Use SmartPayFX only for lawful purposes.
• Notify SmartPayFX if they believe their account or payment information has been compromised.
• Avoid using SmartPayFX to receive, transfer or exchange funds on behalf of unidentified third parties.

Failure to comply with these requirements may result in delays, transaction rejection, account restrictions or termination of access to SmartPayFX services.

20. Policy Review & Changes

SmartPayFX may review and update this AML & KYC Policy periodically to reflect changes in applicable law, regulatory guidance, business activities, payment methods, technology, financial-crime risks or internal procedures.

Updated versions may be published on the SmartPayFX website with a revised effective date. Continued use of services may be subject to the latest applicable version of this Policy.