AML policy

Calypso Pay Ltd AML/CTF AND SANCTIONS REGIME

Calypso Pay Ltd is committed to protect the safety, soundness and reputation of Calypso Pay Ltd by reducing the likelihood that Calypso Pay Ltd will be used as a vehicle for, or become a victim of, Money Laundering or Counter Terrorist Financing (ML/CTF) activities. Furthermore, Calypso Pay Ltd is also committed to comply with applicable Economic Sanctions laws and prevent activities involving sanctions targets.

Anti-Money Laundering Officer (AMLO) is responsible to Senior Management of Calypso Pay for establishing and maintaining Calypso Pay Ltd Anti‑Money Laundering and Anti-Terrorist Financing (AML/CTF) and Sanctions programs.

The AML / CTF and Sanctions programs include the following core elements:

– Oversight by Senior Management

- Documented policies and procedures that address regulatory requirements

– Training for employees and those who act on behalf of Calypso Pay Ltd

– Risk assessments

– Testing of control effectiveness

– Client identification

– Record keeping and retention

– Ongoing monitoring

– Regulatoryreporting

The AML/CTF and Sanctions programs are delivered by employees in the Global Anti‑Money Laundering Policy, made up of teams of specialists who use analytics, innovative technology and professional expertise to detect and deter ML/CTF and manage sanctions compliance.