KYC and KYB Policy

Effective Date: [01-01-2023]

This Know Your Customer and Know Your Business Policy explains how WalletPlug verifies the identity of individuals and businesses using its platform in order to prevent fraud, financial crime, and regulatory violations.

This Policy forms part of and is incorporated into the Platform Terms of Service and Merchant Services Agreement.

1. Purpose

This Policy exists to:

• prevent money laundering and terrorist financing

• verify the identity of users and merchants

• comply with financial regulations

• protect WalletPlug and its partners

WalletPlug applies a risk based approach to all verification.

2. Who Must Be Verified

WalletPlug may require verification for:

• individual users

• business owners and directors

• merchants

• developers accessing payment APIs

Verification is required before certain features, payouts, or transaction limits are enabled.

3. Information Collected

WalletPlug may collect and verify:

a. Individuals

• full legal name

• date of birth

• residential address

• government issued identification

• photographs or biometric verification

b. Businesses

• legal business name

• registration documents

• business address

• nature of business

• ownership and control information

• beneficial owners holding significant control

• bank account details

4. Verification Process

WalletPlug uses:

• automated verification systems

• third-party identity and compliance providers

• manual compliance reviews

WalletPlug may request updated or additional information at any time.

5. Enhanced Due Diligence

WalletPlug may apply enhanced due diligence for:

• high-risk businesses

• large transaction volumes

• cross-border activity

• industries with elevated fraud or regulatory risk

This may include additional documentation, source of funds checks, and ongoing monitoring.

6. Ongoing Monitoring

WalletPlug continuously monitors:

• transaction activity

• account behavior

• compliance indicators

Accounts may be reviewed or restricted if unusual or suspicious activity is detected.

7. Failure to Provide Information

If required information is not provided:

• features may be restricted

• payouts may be delayed

• the account may be suspended or terminated

WalletPlug may retain funds where required by law or risk controls.

8. Data Protection

All verification data is handled in accordance with the Privacy Policy and applicable data protection laws.

WalletPlug uses secure systems and trusted partners to store and process KYC and KYB information.

9. Regulatory Reporting

WalletPlug may report:

• suspicious transactions

• sanctioned individuals

• required regulatory information

to financial institutions or authorities as required by law.

10. Amendments

WalletPlug may update this Policy at any time.

Continued use of the platform constitutes acceptance of the updated Policy.