Purpose

As an Authorized Payment Institution, we are considered to be at potentially higher risk for money laundering and terrorist financing activities. The purpose of this document is to give all staff at

AB Money guidance and remind them of their obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, Proceeds of Crime Act and Terrorism Act 2000 as set out in the AML Policy. Including the update, the UK's AML regime to incorporate international standards set by the Financial Action Task Force (FATF) and to

transpose the EU’s 5th Money Laundering Directive.

The document and its activity may be subject to change and will undergo a periodic compliance

review to ensure adherence to the aforementioned. The Company reserves the right to vary, change, alter, amend, add to or remove any of the terms and conditions of this procedure at any time.

Scope

This document details the information and tools in the identification of clients both private and

corporate, and beneficiaries that will need to be referred to compliance for approval. This is because they are prohibited.

This document lists Industries or items and activities that AB MONEY prohibits working with as it is outside

of the Company’s Risk Appetite. It applies to any person or entity using our payment service and any transactions that we are asked to process.

If we believe or suspect that any transaction violates this policy or is otherwise illegal or unsuitable, we may take any corrective action that we deem appropriate, including blocking the transaction, holding funds associated with a prohibited transaction, suspending, or restricting the use of our service, terminating the accounts of violators, or any other corrective action.

Core Obligations

It is the policy of AB Money to strictly comply with all laws and regulations that apply to any of their activities and operations, or that may give rise to the risk of liability for any of their branches or employees.

It is the duty of all employees to abide by all applicable laws and regulations, and exercise great care not to take or authorize any actions that may create even the appearance of illegal conduct or other impropriety. Staff must not try to falsify the truth or chose not to divulge information, in order to benefit themselves or the customers – this is an illegal offence and the company’s staff, who violate this Policy will be subject to appropriate action.

Prohibited Business

Although there are sanctioned countries that Financial Institution partners will not allow us to facilitate payments to (directly or indirectly) and we screen against various Financial Sanction lists -which the Company will not transfer funds to and have the appropriate controls in place to prohibit. The Company documents its prohibited business list along with its ‘Compliance Approval Required’ so that Compliance can monitor what types of industries are coming to AB Money which may have an impact the Risk Assessment of the firm.

Any item that features on the following list MUST be submitted to the MLRO who will review and respond on how to continue before either a business relationship is approved, or a payment is released.

Countries

For a list of counties that are considered to be higher risk/prohibited, these are listed with the risk rating of “Needs MLRO’s Approval”.

If a client tries to register or pay to any of these listed the transaction will be auto referred to compliance and it put in review required status in AB Money monitoring system (firewall) - where no further action can be taken by anyone except the MLRO.