AML / OFAC Policy

Policy Purpose

Monay Pay, Inc. ("Monay," "we," "us," or "our") maintains this Anti-Money Laundering (AML) and Office of Foreign Assets Control (OFAC) compliance policy to:

• Prevent the use of our services for money laundering, terrorist financing, or other illicit activities
• Comply with the Bank Secrecy Act (BSA) and related anti-money laundering regulations
• Ensure compliance with OFAC sanctions programs
• Protect our users and maintain the integrity of the financial system

Customer Identification Program (CIP)

Before you can use Monay, we verify your identity. This process helps us confirm you are who you say you are and is required by federal law.

Our identity verification process may include:

• Collection of your name, date of birth, address, and Social Security Number
• Verification of a government-issued photo ID (driver's license, passport, etc.)
• Biometric verification to match your photo ID to you
• Address verification through documentary or non-documentary methods

We use identity verification partners such as Persona to help confirm your identity, reduce fraud, and meet compliance requirements.

Know Your Customer (KYC)

Beyond initial identity verification, we conduct ongoing due diligence to understand our customers and their use of our services. This includes:

• Assessing customer risk profiles
• Understanding expected transaction patterns
• Enhanced due diligence for higher-risk accounts
• Periodic review of customer information

OFAC Sanctions Screening

Monay screens all users and transactions against sanctions lists maintained by the Office of Foreign Assets Control (OFAC), including:

• Specially Designated Nationals and Blocked Persons List (SDN List)
• Sectoral Sanctions Identifications List
• Other OFAC sanctions programs as applicable

We are prohibited from conducting business with individuals or entities on these lists and must block or reject any such transactions.

Transaction Monitoring

We monitor transactions for suspicious activity that may indicate money laundering, fraud, or other financial crimes. Our monitoring includes:

• Automated transaction monitoring systems
• Pattern analysis to detect unusual activity
• Manual review of flagged transactions
• Investigation of suspicious behavior

Suspicious Activity Reporting

If we detect activity that we know, suspect, or have reason to suspect involves potential money laundering or other financial crimes, we are required to file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN). We are prohibited by law from disclosing to you that a SAR has been filed.

Recordkeeping

We maintain records of customer identification information, account activity, and compliance documentation as required by the Bank Secrecy Act. Records are retained for a minimum of five years and may be retained longer as required for compliance, fraud prevention, dispute resolution, or legal obligations.

Enforcement Actions

Monay and/or its regulated partners may take the following actions where required by law or policy:

• Request additional information or documentation
• Delay or decline transactions
• Restrict account functionality
• Freeze or suspend account access
• Close accounts
• Report suspicious activity to appropriate authorities

Partner Coordination

Monay works with regulated partners to fulfill our compliance obligations. Our partners may include:

• Persona - Identity verification and fraud prevention
• Stripe - Payment processing, KYC/KYB verification, and compliance
• Cross River Bank - Banking infrastructure and regulatory compliance
• Circle - USDC stablecoin compliance
• Coinbase - Digital asset custody and compliance
• Fiserv - Enterprise payment processing compliance

These partners may perform compliance functions on our behalf or as independent obligations under applicable law.

Contact Us

If you have questions about this policy, please contact us at: