P2P Funds Movement Policy

1. Purpose
This policy establishes the procedures our business follows to identify and mitigate risks related to money laundering, fraud, and sanctions screening in peer-to-peer (P2P) fund transfers within our app. It also defines restrictions to prevent unauthorized access and fund movement by users outside our specified jurisdiction.

2. Compliance with Anti-Money Laundering (AML) and Fraud Prevention Regulations
Our business is committed to adhering to all relevant AML, Know Your Customer (KYC), and fraud prevention regulations. The following measures are implemented to mitigate risks:

· Customer Verification (KYC): Users must complete identity verification before accessing fund transfer features. This includes government-issued ID verification, biometric authentication, and proof of address.

· Transaction Monitoring:All transactions are monitored for suspicious activity, including rapid transfers, large amounts, and unusual patterns that may indicate fraud or money laundering.

· Reporting Suspicious Activity: Any suspicious transactions are reported to the relevant financial authorities in compliance with applicable laws.

3. Sanctions Screening and Risk Mitigation
To prevent transactions involving sanctioned individuals or entities, we employ the following controls:

· Sanctions Screening:Users and transactions are screened against government and international sanctions lists (e.g., OFAC, UN, EU, and local authorities).

· Automated Blocking:Transactions that trigger sanctions alerts are automatically blocked, and users may be subject to further review.

· Enhanced Due Diligence (EDD): High-risk transactions undergo additional verification before approval.

4. Geographic Restrictions and Access Controls
To prevent unauthorized access and fund movement outside our specified jurisdiction, we enforce the following:

· Geo-Blocking:The app restricts access from IP addresses and phone numbers registered outside permitted regions.

· Payment Method Restrictions: Only payment methods issued within approved jurisdictions are accepted.

· Regular Compliance Audits: Our system undergoes periodic reviews to ensure compliance with jurisdictional restrictions.

5. Transaction Limits and Controls
To mitigate fraud and unauthorized activity, we impose the following transaction limits:

· Daily and Monthly Limits: Users are subject to predefined daily and monthly transaction limits based on their account tier and verification level.

· Tiered Access:Higher transaction limits are granted only to users with additional verification (e.g., business accounts, long-term users).

· Velocity Checks:Limits on the number of transactions per hour/day to prevent rapid fund movement.

6. Enforcement and Policy Review
Our business regularly reviews and updates this policy to ensure compliance with regulatory changes and industry best practices. Violations of this policy may result in account suspension, termination, and reporting to relevant authorities.

7. User Acknowledgment
All users must acknowledge and agree to this policy before using P2P fund movement features within our app. Failure to comply with these procedures may lead to account restrictions or legal consequences.