KYC Policy

Purpose

This KYC Policy outlines the procedures implemented by Ex Payments Ltd to verify the identity of merchants and business partners prior to establishing a commercial relationship.

Ex Payments Ltd is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and implements this policy in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

The purpose of this policy is to:

• Prevent misuse of payment infrastructure
• Mitigate fraud and financial crime risk
• Comply with applicable Canadian laws and sanctions requirements
• Support responsible onboarding of merchant clients

Ex Payments Ltd applies a risk-based approach to customer identification and verification.

Scope

This policy applies to:

• Merchant onboarding
• Corporate client verification
• Ultimate beneficial owner identification
• Ongoing monitoring of merchant activity

Ex Payments Ltd primarily provides services to business entities and does not onboard individual retail consumers.

Definitions

KYC means Know Your Customer procedures used to verify identity.

KYB means Know Your Business procedures used to verify corporate entities, ownership structure, and legal existence.

CDD means Customer Due Diligence, the process of assessing risk and verifying identity prior to establishing a business relationship.

EDD means Enhanced Due Diligence applied to higher-risk clients.

UBO means Ultimate Beneficial Owner, being the natural person who ultimately owns or controls a legal entity.

Sanctions mean economic or financial restrictions imposed by Canada or other applicable authorities.

Merchant Onboarding Process

Prior to approving a merchant relationship, Ex Payments Ltd collects and verifies:

• Legal company name
• Business registration number
• Registered address
• Nature of business activities
• Ownership structure
• Identification of directors
• Identification of ultimate beneficial owners

Documentation may include:

• Certificate of incorporation
• Articles of incorporation
• Corporate registry extracts
• Government-issued identification of UBOs
• Proof of business address
• Website and operational review

All onboarding applications are reviewed for consistency, completeness, and risk exposure.

Approval of any merchant relationship is subject to the sole discretion of Ex Payments Ltd following completion of internal compliance, risk, and underwriting review.

Risk-Based Assessment

Ex Payments Ltd applies a structured risk assessment during onboarding.

Risk factors considered include:

• Industry category
• Geographic exposure
• Transaction model
• Expected volume
• Chargeback risk
• Ownership structure complexity
• Adverse media screening
• Sanctions exposure

Merchants are assigned a risk category, and appropriate due diligence measures are applied accordingly.

Ex Payments Ltd reserves the right to approve, conditionally approve, decline, or terminate a merchant relationship based on its internal risk assessment framework.

Enhanced Due Diligence

Enhanced Due Diligence may be applied where higher risk indicators are identified.

Examples include:

• High-risk industries
• Cross-border operations
• Complex ownership structures
• Elevated expected transaction volume
• Association with high-risk jurisdictions

EDD may require:

• Additional corporate documentation
• Source of funds declarations
• Additional ownership verification
• Senior management approval

Sanctions and Restricted Jurisdictions

Ex Payments Ltd does not establish relationships with individuals or entities subject to applicable sanctions.

Screening is conducted against publicly available sanctions lists, including those issued by Canadian authorities and other recognized international bodies.

Merchants located in, incorporated in, or primarily operating from high-risk or restricted jurisdictions may be declined or subject to enhanced review.

Ongoing Monitoring

Merchant relationships are subject to continuous transaction monitoring and periodic compliance review. Ex Payments Ltd actively monitors merchant transaction activity to detect unusual patterns, elevated chargeback ratios, fraud indicators, sanctions exposure, and other risk factors.

This may include:

• Periodic review of business information
• Monitoring of transaction patterns
• Review of chargeback ratios
• Review of complaints or regulatory concerns
• Reverification of documentation, where necessary

Where monitoring identifies elevated risk, suspicious activity, or breach of contractual terms, Ex Payments Ltd may impose reserves, delay settlement, suspend processing, request additional documentation, or terminate the merchant relationship.

Re Verification

Merchants may be required to provide updated documentation in cases such as:

• Change in ownership
• Change in directors
• Change in business model
• Significant increase in transaction volume
• Regulatory request
• Periodic compliance review

Failure to provide requested documentation may result in suspension or termination of services.

Record Keeping

Onboarding and verification records are retained for a period consistent with applicable Canadian legal and regulatory requirements.

Records are stored securely, and access is restricted to authorized personnel.

Reporting and Escalation

Where suspicious activity or potential fraud is identified, Ex Payments Ltd may:

• Escalate internally
• Request additional documentation
• Suspend onboarding
• Decline the application
• File required reports with FINTRAC, notify relevant financial partners where applicable, and take appropriate action, including suspension, fund holds, or termination of the merchant relationship.

All decisions are documented internally.

Training and Governance

Personnel involved in onboarding and compliance functions receive periodic training regarding fraud detection, sanctions screening, and risk assessment procedures.

Senior management oversees the implementation of this policy.

Policy Review

This policy is reviewed periodically and updated as necessary to reflect regulatory developments or operational changes.

Contact

For questions regarding our KYC Policy, please contact:

Ex Payments Ltd 2709b 43rd Avenue Vernon, British Columbia V1T 3L2 Canada

Phone: +1 778 744 4578 Email: info@ex-payments.com