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AML CFT AND CPF POLICY

countering money laundering, financing of terrorism, and the proliferation of weapons of mass destruction

Edition: 1.0
Effective date: October 30, 2026

1. GENERAL PROVISIONS

1.1. This AML/CFT/CPF Policy (hereinafter — the “Policy”) establishes the public principles applied by TRANZA LLC in preventing money laundering, terrorism financing, the financing of the proliferation of weapons of mass destruction, fraud, and other financial crimes within AirPOS.

1.2. The AirPOS operator is TRANZA LLC, a company registered under the laws of Saint Vincent and the Grenadines with registration number 4527 LLC 2026, with its registered office at: Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines (hereinafter referred to as “TRANZA”, the “Operator” or “we”).

1.3. The policy was developed taking into account the Money Services Business model of class F. In accordance with the legislation of Saint Vincent and the Grenadines, class F may cover all or a combination of types of money services business provided for in classes A-E. TRANZA engages only in those types of activities that are permitted by the applicable license, regulatory conditions, and are actually available through AirPOS.

1.4. The policy applies to Applicants, Merchants, their officers, participants, ultimate beneficial owners, representatives and Authorized Users, Payers as applicable, as well as to employees, agents, contractors, and TRANZA Payment Partners within their respective functions.

1.5. TRANZA does not allow the conscious use of AirPOS for illegal activities and applies risk-based measures proportional to the nature of the services, client base, geography, service channels, and volume of operations.

1.6. Policy is a public description of the control system. Detailed risk criteria, monitoring scenarios, threshold values, sources of checks, procedures for internal investigations, and the content of reports to competent authorities are considered internal procedures and are not disclosed unless otherwise provided by law.

2. TERMS

AML — measures against money laundering.

CFT — measures to counteract the financing of terrorism.

CPF — measures to counteract the financing of the proliferation of weapons of mass destruction.

FSA — Financial Services Authority of Saint Vincent and the Grenadines.

FIU — Financial Intelligence Unit of Saint Vincent and the Grenadines.

MSB — Money Services Business in the meaning of the applicable law of Saint Vincent and the Grenadines.

Merchant — an entrepreneur or organization connected to AirPOS to accept payments for their own goods, works, or services.

The Payer is the person initiating the payment in favor of the Merchant.

Client — an applicant, Merchant, or other person with whom TRANZA establishes or maintains business relations.

Authorized user — an employee, cashier, representative, developer, or other person to whom the Merchant has granted access to AirPOS.

UBO — an individual who ultimately owns the Client, controls it, or in whose interest business relationships are established or a transaction is conducted.

PEP is a politically exposed person, as well as a member of their family or a close associate to the extent established by applicable law.

A payment partner is a bank, acquirer, issuer, processing organization, payment system, or another participant of the payment infrastructure.

A transaction is an operation initiated or processed through AirPOS using a supported fiat payment instrument.

SAR — a report of suspicious activity or operation sent to FIU in cases provided by law.

MLRO is the appointed person responsible for receiving and evaluating internal messages and directing SAR to FIU.

MLCO is the designated person responsible for overseeing and monitoring compliance with AML/CFT/CPF requirements.

3. REGULATORY FRAMEWORK

3.1. The AML/CFT/CPF TRANZA system is built taking into account the applicable requirements of Saint Vincent and the Grenadines, including:

  • Money Services Business Act, Cap. 260, with subsequent amendments, including the Money Services Business (Amendment) Act 2022;
  • Financial Services Authority Act 2011;
  • Proceeds of Crime Act 2013 and applicable amendments;
  • Anti-Money Laundering and Terrorist Financing Regulations 2014 and applicable amendments, including the amendments of 2017 and 2024;
  • Anti-Money Laundering and Terrorist Financing Code 2017;
  • Anti-Money Laundering and Terrorist Financing (Administrative Penalties) Regulations 2024;
  • Anti-Terrorism Act 2023;
  • Anti-Terrorist Financing and Proliferation Act 2017;
  • mandatory instructions, conditions, guidelines, and requirements FSA and FIU.

3.2. TRANZA also takes into account the applicable recommendations of Financial Action Task Force and recognized international standards for managing financial crime risks to the extent that they are consistent with mandatory legislation.

3.3. If a mandatory requirement of the legislation, regulator, or competent authority establishes a stricter measure than this Policy, such mandatory requirement shall apply.

4. GOALS AND MAIN PRINCIPLES

4.1. The objectives of the Policy are:

  • prevention of the use of TRANZA and AirPOS for money laundering, financing of terrorism, and the proliferation of weapons of mass destruction;
  • identification, assessment, documentation, and mitigation of financial crime risks;
  • establishing the identity and business profile of the Client and related persons;
  • identification of UBO, PEP, sanction-related and other high-risk factors;
  • monitoring of business relations and transactions;
  • timely internal review of unusual and suspicious activity;
  • sending SAR and other mandatory messages to the competent authorities;
  • maintaining an adequate audit trail;
  • maintaining effective management, training, independent oversight, and regulatory interaction.

4.2. TRANZA applies the following principles:

  • the risk is assessed before establishing relationships and on an ongoing basis;
  • the depth of the review corresponds to the identified risk;
  • the absence of documented understanding of the Client and their activities precludes the initiation or continuation of service;
  • Commercial interest does not take priority over mandatory AML/CFT/CPF requirements;
  • Decisions and inspection results are documented to an extent sufficient for subsequent control;
  • Information about SAR, internal investigations, and monitoring methods is kept confidential.

5. MANAGEMENT AND RESPONSIBILITY

5.1. The highest governing body of TRANZA bears overall responsibility for the presence of an effective AML/CFT/CPF system, approves the main policies, provides sufficient resources, and reviews regular management reporting.

5.2. TRANZA appoints MLRO and MLCO in accordance with applicable requirements. The appointed persons must have sufficient competence, independence, seniority, resources, and access to information.

5.3. MLRO:

  • receives and evaluates internal messages about suspicious activity;
  • determines the need to send SAR to FIU;
  • directs SAR and interacts with FIU within its authority;
  • documents the decision to send or not to send the message;
  • ensures the confidentiality of information and compliance with the tipping-off prohibition.

5.4. MLCO:

  • monitors compliance with legislation and internal procedures;
  • coordinates the institutional risk assessment;
  • ensures the relevance of procedures, training, and quality control;
  • organizes the elimination of identified deficiencies;
  • is the contact person for FSA and other competent authorities on compliance matters within the scope of the powers granted.

5.5. The functions MLRO and MLCO can be combined by one person only with the required regulatory approval. Outsourcing individual compliance functions does not relieve TRANZA and its management bodies from responsibility.

5.6. Employees, agents, and contractors must comply with applicable procedures, promptly escalate suspicions, and not impede MLRO or MLCO in performing their duties.

6. INSTITUTIONAL RISK ASSESSMENT

6.1. TRANZA conducts and documents the assessment of inherent and residual risks of ML/TF/PF taking into account:

  • types of Clients and their ownership structure;
  • products and services of MSB, actually provided through AirPOS;
  • types of Transactions, currencies, and payment instruments;
  • jurisdictions of Clients, Payers, recipients, and Payment partners;
  • methods of connection and service channels, including remote ones;
  • Merchants, websites, applications, points of sale, and sales models;
  • the estimated and actual volumes, frequency, and nature of operations;
  • risks of agents, intermediaries, suppliers, and outsourcing;
  • new technologies, products, and significant changes in the business model;
  • results of the national risk assessment SVG, regulatory guidance, and internal experience.

6.2. The assessment is reviewed periodically and in the event of significant changes in services, geography, client base, threats, legislation, or the control environment.

6.3. TRANZA does not launch a new product, service, payment method, channel, or significant technological change without a prior assessment of the associated risks and identification of the necessary control measures.

7. CLIENT RISK AND CLASSIFICATION

7.1. Each Client is assigned a documented risk profile before activating services. The classification may take into account standard and elevated risk levels or a more detailed internal scale.

7.2. Risk factors may include:

  • jurisdiction of registration, activity, and settlements;
  • form of ownership, complexity of structure, and transparency of control;
  • type of business, products, services, licenses, and sales channels;
  • actual presence and economic justification of activity;
  • expected volumes, average size, frequency, and directions of operations;
  • sources of funds, origin of the business, and, if necessary, source of wealth;
  • the presence of PEP, sanction matches, negative information, or regulatory history;
  • the use of intermediaries, nominal persons, agents, or third parties;
  • discrepancy in the information provided to different participants of the inspection;
  • the inability to verify the stated facts with independent sources.

7.3. The risk profile is reviewed when there is a change in ownership, management, activity, website, geography, payment behavior, sanctions status, or other material information.

7.4. TRANZA is not obligated to disclose to the Client the internal rating, monitoring scenarios, or other information the disclosure of which may reduce the effectiveness of control.

8. CUSTOMER DUE DILIGENCE

8.1. TRANZA conducts Customer Due Diligence before establishing business relations, as well as in other cases provided by law or internal procedures.

8.2. CDD includes depending on the type of Client and risk:

  • establishment and verification of the Client’s identity using reliable independent data;
  • verification of the authority of the person acting on behalf of the Client;
  • identification and verification of UBO;
  • understanding of the purpose and the intended nature of the relationship;
  • formation of the expected profile of activity and Transactions;
  • checking applicable sanctions, PEP, and other risk factors;
  • constant monitoring and updating of information.

8.3. TRANZA does not establish or support anonymous relationships, relationships under an obviously fictitious name, or relationships in which mandatory identification cannot be completed.

8.4. If CDD cannot be completed, TRANZA refuses activation, limits or terminates the relationship, and considers the need to send SAR without notifying the Client of such consideration.

8.5. Simplified measures may be applied only in cases of low risk and when there is a legal basis. Simplified verification is not applied if there is suspicion of ML/TF/PF or in the presence of increased risk.

9. KYC INDIVIDUALS

9.1. In cases where an individual is a Client, UBO, director, representative, Authorized User, or other verified person, TRANZA may receive and verify:

  • full name, date and place of birth, citizenship;
  • residential address and contact details;
  • a valid identity document;
  • information about employment, activities, and powers;
  • the purpose of the relationship and the expected nature of operations;
  • source of funds and, in case of increased risk, a source of wealth;
  • other information required by law or taking into account the risk.

9.2. The inspection may be carried out directly by TRANZA or with the involvement of a specialized provider. Using a provider does not exempt TRANZA from the obligation to assess the adequacy and reliability of the results.

9.3. Documents must be valid, legible, consistent, and suitable for independent verification. TRANZA has the right to request certification, translation, the original, additional documentation, or confirmation from an independent source.

10. KYB OF LEGAL ENTITIES AND OTHER ORGANIZATIONS

10.1. For the corporate Client TRANZA establishes and checks how applicable:

  • full name, legal form, registration number and date of registration;
  • registered and actual address;
  • founding and registration documents;
  • directors, managers, and persons authorized to act on behalf of the Client;
  • the ownership and control structure up to individuals UBO;
  • business purpose, actual activities, licenses and permits;
  • websites, applications, retail outlets, brands, and sales channels;
  • the main categories of goods and services, clients and counterparties;
  • the estimated volumes, currencies, geography, and nature of the Transactions;
  • banking and settlement details;
  • financial statements, contracts, tax or other confirmations, when necessary.

10.2. TRANZA checks the legal status using reliable independent sources and assesses whether the stated activity corresponds to the available data.

10.3. The client is obliged to promptly inform about any changes in ownership, control, management, activities, licenses, addresses, websites, points of sale, brands, geography, or payment profile.

10.4. An opaque, overly complex, or economically unjustified structure requires additional explanation and may result in EDD or refusal of service.

11. BENEFICIAL OWNERSHIP AND CONTROL

11.1. TRANZA takes reasonable steps to identify and verify the natural persons who ultimately own or control the Client, in accordance with the criteria of applicable law.

11.2. The check is not limited to the immediate shareholder and covers the ownership chain, voting rights, contractual rights, the ability to appoint management, and other forms of de facto control.

11.3. If UBO cannot be identified through ownership or control after taking reasonable measures, TRANZA applies the legally provided alternative procedure for identifying the senior managing official and documents the actions taken. Such a procedure is not used to conceal uncertainty or contradictions in the structure.

11.4. Nominal shareholders, nominal directors, trusts, funds, partnerships, and similar structures are subject to verification taking into account founders, beneficial owners, protectors, beneficiaries, partners, and other controlling persons, to the extent applicable.

12. PEP AND RELATED PARTIES

12.1. TRANZA takes measures to determine whether the Client, UBO, or another related party is PEP.

12.2. Measures provided by law and the risk profile are applied in relation to PEP, including:

  • obtaining proper approval before establishing or continuing relationships;
  • establishment of the source of wealth and the source of funds;
  • enhanced continuous monitoring;
  • more frequent data updating.

12.3. The PEP status does not imply an automatic denial of service. The decision is made based on a documented risk assessment and the ability to implement sufficient control measures.

13. ENHANCED DUE DILIGENCE

13.1. EDD is used in cases of increased risk, including situations associated with:

  • PEP;
  • high-risk jurisdiction or cross-border structure;
  • complex or opaque property;
  • an activity, product, or channel of increased risk;
  • unusually large, complex, or economically non-obvious operations;
  • negative information or significant regulatory violations;
  • mismatch between the declared and actual profile;
  • remote connection in case of insufficiency of standard measures;
  • by other factors established by law, FSA, FIU, or internal assessment.

13.2. EDD may include:

  • additional identification and corporate documents;
  • independent verification of activities, address, and authority;
  • a deeper analysis of the ownership structure and counterparties;
  • confirmation of the source of funds and source of wealth;
  • analysis of the economic purpose and the expected route of funds;
  • approval of the authorized senior manager;
  • increased or more frequent monitoring;
  • restriction of products, geography, limits, or service channels.

13.3. If the risk cannot be understood or reduced to a level corresponding to the risk appetite and mandatory requirements, TRANZA does not establish or terminates business relationships.

14. SANCTIONS AND FUNDING OF PROLIFERATION

14.1. TRANZA checks Clients and applicable related parties against sanctions and restrictive lists required for TRANZA, a specific Transaction, or the relevant Payment Partner.

14.2. The control covers applicable targeted financial sanctions, including measures related to terrorism, terrorist financing, and the proliferation of weapons of mass destruction.

14.3. The check is carried out upon connection and subsequently at a frequency corresponding to the risk and updates of applicable lists. A potential match is analyzed taking into account identifiers, context, and the risk of a false match.

14.4. Upon confirmed match or other mandatory grounds, TRANZA blocks, rejects, freezes, or otherwise restricts the operation or relationship and sends messages to the competent authorities in the manner prescribed by law.

14.5. TRANZA does not notify the affected party about actions and messages to the extent that notification is prohibited by law or may impede an investigation.

15. GEOGRAPHICAL RISK

15.1. Geographical risk is assessed taking into account:

  • sanctions and targeted financial restrictions;
  • instructions FSA, FIU and applicable international bodies;
  • strategic shortcomings of the AML/CFT/CPF mode;
  • the level of corruption, organized crime, terrorism, and financial fraud;
  • transparency of corporate registers and availability of reliable data;
  • the economic justification of the Client’s connection with the relevant jurisdiction.

15.2. TRANZA has the right to exclude a particular country or territory from service or to establish EDD, additional documents, restrictions on products, operations, and settlements.

15.3. The accessibility of a website or the technical ability to initiate an action does not mean that the corresponding service is permitted or available in a specific jurisdiction.

16. CONSTANT MONITORING

16.1. TRANZA carries out continuous monitoring of business relationships and transactions in order to assess their compliance with the known customer profile, their activities, source of funds, and the stated purpose of the service.

16.2. Monitoring may take into account:

  • the amount, frequency, speed, and total volume of transactions;
  • currency, geography, time, and the payment channel used;
  • deviation from expected turnover or seasonality;
  • mismatch of Transactions with the Merchant’s goods, services, website, or business model;
  • a sharp increase in activity after a period of inactivity;
  • an unusual share of deviations, Refund or Chargeback;
  • artificial fragmentation or a related sequence of operations;
  • the use of multiple payers, devices, points of sale, or details with atypical connections;
  • payments in favor of third parties or signs of payment aggregation;
  • atypical returns, circular movement or lack of a clear economic purpose;
  • information of Payment Partners, complaints, disputes, and results of previous inspections.

16.3. Monitoring scenarios and parameters are regularly evaluated and adjusted taking into account risks, false positive results, new typologies, and the requirements of competent authorities.

16.4. The triggering of a rule or other indicator is not in itself evidence of an offense and requires analysis in the context of the available information.

17. MERCHANT AND PAYMENT TRAFFIC CONTROL

17.1. TRANZA checks the compliance of actual payment traffic with the activities approved when the Merchant was connected.

17.2. The merchant is not entitled to, without prior agreement:

  • to accept payments on behalf of another seller or for the benefit of a third party;
  • to carry out payment aggregation, re-acquiring, or provide AirPOS to another person;
  • to direct unsolicited, forwarded, or mixed traffic;
  • to use an unregistered website, application, brand, domain, or point of sale;
  • to accept payments for goods or services that significantly differ from the approved model;
  • to hide the actual seller, the purpose of the payment, MCC, or the place of the transaction;
  • artificially separate operations to bypass limits or control measures.

17.3. TRANZA can match Transactions with orders, payment requests, receipts, contracts, proofs of delivery, return policies, website information, and other supporting materials.

17.4. A discrepancy between the declared and actual traffic may lead to a request for documents, increased monitoring, function limitation, risk profile review, or termination of service.

18. PAYER AND TRANSFER DETAILS

18.1. For money transmission and other applicable operations, TRANZA ensures the collection, verification, storage, and transmission of information about the sender and recipient to the extent required by law and the rules of the relevant payment infrastructure.

18.2. Insufficiency of mandatory information may lead to rejection, suspension, a request for additional information, or enhanced scrutiny of the transaction.

18.3. The Merchant and the Payer must not provide fictitious, misleading, or belonging to another person information and must not include excessive sensitive information in the payment purpose.

19. SOURCE OF FUNDS AND SOURCE OF WEALTH

19.1. TRANZA has the right to request information and documents confirming the source of funds used in a specific transaction or within the framework of business relations.

19.2. In case of increased risk, TRANZA may also establish the source of the Client’s wealth, UBO or PEP.

19.3. Confirmation may include financial statements, bank statements, tax documents, contracts, documents on the sale of property, inheritance, investments, wages, dividends, or other reliable information appropriate to the circumstances.

19.4. The presence of the document by itself does not eliminate risk. TRANZA assesses its authenticity, origin, correspondence to the amount, timing, participants, and the economic sense of the operation.

20. AGENT PARTNERS AND OUTSOURCING

20.1. Before engaging an agent, Payment Partner, KYC/KYB-supplier, processing organization, or other significant supplier, TRANZA conducts a check commensurate with their role and risk.

20.2. The check may include legal status, licenses, ownership, reputation, geography, AML/CFT/CPF system, sanctions risks, security, the ability to provide data, and contractual rights TRANZA for control.

20.3. The contracts provide for necessary access to data and documents, confidentiality, security, incident notification, assistance in inspections, and the possibility of terminating relations in case of unacceptable risk.

20.4. TRANZA does not rely on a third party if it cannot timely obtain the necessary CDD data and documents or verify the adequacy of the measures applied.

20.5. The use of an agent, supplier, or Payment Partner does not exclude TRANZA’s own liability to the extent established by law.

21. PROHIBITED AND RESTRICTED ACTIVITIES

21.1. AirPOS is prohibited for use in:

  • money laundering, financing of terrorism, or proliferation of weapons of mass destruction;
  • fraud, theft, use of stolen payment data;
  • circumvention of sanctions, asset freezes, limits, or mandatory control measures;
  • illegal trafficking of drugs, weapons, human trafficking, and other crimes;
  • concealment of the actual seller, payer, recipient, or beneficiary;
  • the use of front people, fictitious companies or documents;
  • operations without a legitimate economic purpose or with an obviously false designation;
  • activities prohibited by law, the rules of the payment system, or the contract.

21.2. TRANZA establishes a list of prohibited and restricted categories of business. A high-risk category can be served only if there is a legal basis, the necessary permits, and sufficient control measures.

21.3. The absence of a specific category in the public list does not mean automatic approval.

22. UNUSUAL AND SUSPICIOUS ACTIVITY

22.1. Employees, agents, and other persons to whom the internal procedures TRANZA apply are required to immediately send an internal message to MLRO if they have knowledge, suspicion, or reasonable grounds for suspicion of ML/TF/PF or another financial crime.

22.2. MLRO analyzes the message and available information, has the right to request additional information, and determines the need for SAR in accordance with the law.

22.3. When directing SAR, TRANZA cooperates with FIU and provides additional information within the limits of legal requirements.

22.4. The non-referral of SAR after internal review is documented with the reasons specified.

22.5. TRANZA is not required to prove the commission of a crime in order to refer SAR. Suspicion is not a public accusation and does not imply the established guilt of a person.

23. PROHIBITION OF TIPPING OFF AND CONFIDENTIALITY

23.1. TRANZA does not inform the Client or any other unauthorized person about the direction, intended direction or content of SAR, internal message, request FIU or actions whose disclosure is prohibited by law.

23.2. A request for additional documents, delay, refusal, or restriction of an operation can only be explained to the extent that does not disclose protected information and does not impede verification.

23.3. Access to the materials of internal messages, SAR, and investigations is provided only to authorized personnel on a need-to-know basis.

24. TEMPORARY RESTRICTIONS AND REFUSAL

24.1. Within the limits of the law and contractual terms, TRANZA has the right to reject, suspend, restrict, or terminate an operation, function, or business relationship if:

  • mandatory check not completed;
  • information or documents are unreliable, incomplete, or contradictory;
  • the transaction does not correspond to a known profile or has an unclear economic purpose;
  • signs of fraud, sanction prohibition, or unacceptable risk have been identified;
  • an obligatory order from a competent authority has been received;
  • The client does not provide the requested information or hinders the inspection;
  • Continuing the relationship would violate the law, a licensing condition, a payment infrastructure rule, or TRANZA’s risk appetite.

24.2. The restriction is applied to the extent and for the period necessary for the respective lawful purpose. AML/CFT/CPF-check itself is not considered a basis for indefinite retention of funds without a legal or contractual ground.

24.3. Termination of service, refund, or transfer of the allowable balance is carried out in accordance with the law, sanctions, mandatory orders, rights of Payment Partners, and contractual terms.

24.4. TRANZA may not disclose the specific grounds for the decision if disclosure is prohibited by law, creates a risk to tipping-off, reveals confidential control methods, or violates the rights of third parties.

25. DOCUMENT STORAGE

25.1. TRANZA stores CDD/KYC/KYB documents, information about UBO, correspondence, risk assessments, and business relationship documents for at least seven years after the termination of the corresponding relationships or longer if required by law or a competent authority.

25.2. Records of Transactions and supporting documents are kept for at least seven years from the date of completion of the corresponding operation or longer if required by law.

25.3. Records must be sufficient to reconstruct a particular transaction, create an audit trail, analyze the financial profile, and provide it in a timely manner to the competent authority.

25.4. May be subject to storage:

  • identification and corporate documents;
  • information about UBO, representatives, and authorities;
  • results of sanction, PEP and other checks;
  • risk profiles, EDD and approvals;
  • information about Transactions, Refund, Chargeback, and settlements;
  • contracts, payment instructions, checks, invoices, and delivery confirmations;
  • internal messages, MLRO decisions, and investigation materials;
  • documents on training, testing, and independent evaluation.

25.5. Documents are protected against unauthorized access, alteration, loss, and destruction and must be available within a reasonable time to FSA, FIU, and other competent authorities within their powers.

26. TRAINING AND STAFF ASSESSMENT

26.1. TRANZA applies proportionate measures to verify the integrity, competence, and reliability of employees performing functions related to payments, clients, risk, and AML/CFT/CPF.

26.2. Employees undergo introductory and periodic training according to their role. The training covers:

  • applicable duties and internal procedures;
  • typologies and indicators ML/TF/PF and fraud;
  • CDD, EDD, sanctions, PEP and UBO;
  • monitoring and internal reporting of suspicions;
  • tipping-off ban and confidentiality;
  • storage of documents and protection of information;
  • consequences of non-compliance with requirements.

26.3. TRANZA documents the content, date, participants, and results of training and, if necessary, conducts a knowledge check.

27. INDEPENDENT INSPECTION AND QUALITY CONTROL

27.1. The effectiveness of the AML/CFT/CPF system is subject to periodic independent review, taking into account the size, complexity, and risk profile of TRANZA.

27.2. The check may be carried out by an internal auditor, an independent department, or a qualified external specialist who is not responsible for the daily execution of the procedures being audited.

27.3. The following are evaluated, in particular:

  • relevance of institutional risk assessment;
  • the quality of CDD, EDD and the detection of UBO;
  • sanctions control and transaction monitoring;
  • internal escalations and MLRO decisions;
  • document storage and regulatory reporting;
  • training, resources, and independence of control functions;
  • implementation of previously issued recommendations.

27.4. Significant deficiencies are brought to the attention of the highest governing body, documented, and eliminated within the established deadlines.

28. DATA PROTECTION AND INFORMATION EXCHANGE

28.1. AML/CFT/CPF data is processed in accordance with the AirPOS Privacy Policy and applicable law, taking into account special obligations regarding collection, storage, disclosure, and confidentiality.

28.2. TRANZA may exchange necessary data with FSA, FIU, law enforcement and other competent authorities, Payment partners, agents, and providers, when it is provided for by law, contract, or necessary for a legitimate AML/CFT/CPF purpose.

28.3. Rights to access, deletion, restriction, and disclosure of information may be limited by mandatory retention periods, the tipping-off prohibition, confidentiality of investigations, sanction requirements, and the protection of the rights of others.

29. COOPERATION WITH FSA FIU AND OTHER BODIES

29.1. TRANZA cooperates with FSA, FIU and other competent authorities within the limits of their legal powers.

29.2. TRANZA provides mandatory reporting, documents, and information in the prescribed manner and ensures the availability of relevant employees and records for supervisory activities.

29.3. The request is checked for authority, scope, and the applicable procedure for execution. This does not limit the obligation to promptly comply with the requirement if such procedure is established by law.

29.4. TRANZA ensures the preservation of documents related to inspection, investigation, disposition, or dispute, even if the general retention period has expired, as long as there is a legal basis.

30. VIOLATIONS AND RESPONSIBILITY

30.1. Violation of the Policy by an employee, agent, or contractor may result in restricted access, disciplinary action, termination of relations, reimbursement of losses, and the transfer of information to the competent authority in cases provided by law.

30.2. A breach by the Client may lead to additional verification, restriction or termination of services, withholding within legal grounds, notification of the competent authority, and other measures provided for by the contract and by law.

30.3. The application of an internal measure does not replace administrative, civil, or criminal liability provided for by law.

31. POLICY REVIEW

31.1. The policy is reviewed periodically and when there are changes in SVG legislation, regulatory expectations, services, risks, TRANZA structure, or the control environment.

31.2. The current version is published on the official AirPOS website with the indication of the effective date.

31.3. Internal procedures, monitoring scenarios, and risk methodologies may be updated without publication if the changes do not affect information that must be disclosed publicly.

32. CONTACT INFORMATION

For general questions about AML/CFT/CPF and compliance, you can contact TRANZA:

TRANZA LLC
Registration No.: 4527 LLC 2026
Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines
Email: info@tranza.io

This address is not intended for internal reports of suspicious activity by TRANZA personnel or for official SARs. Such reports must be submitted exclusively through the secure channels established by internal procedures and applicable law.a