ParlyPay is committed to maintaining a comprehensive compliance programme designed to prevent money laundering, terrorist financing, fraud, sanctions violations, and other financial crimes. Our compliance framework is risk-based, technology-driven, and embedded throughout the customer lifecycle—from onboarding and identity verification to transaction monitoring, ongoing due diligence, and regulatory reporting.

Our program includes written policies and procedures, designated compliance oversight, employee training, independent testing, enterprise-wide risk assessments, recordkeeping, and continuous monitoring to support a secure, transparent, and compliant cross-border payments and escrow platform.

Customer Identification Programme (CIP / KYC)

ParlyPay verifies the identity of customers before they are permitted to access regulated financial services. Identity verification requirements vary depending on customer type, jurisdiction, product, and risk profile.

Individual Customers

Customers may be required to provide:

• Full legal name
• Date of birth
• Residential address
• Government-issued photo identification
• Selfie or liveness verification
• Email verification
• Mobile phone verification

To enhance account security and fraud prevention, ParlyPay may also utilize device intelligence, IP address analysis, geolocation verification, and other risk-based authentication measures where permitted by applicable law.

Business Customers (KYB)

Business accounts may be required to provide the following:

• Business registration information
• Certificate of incorporation or equivalent registration documents
• Registered business address
• Tax identification details (where applicable)
• Information regarding directors and authorised representatives
• Identification of Ultimate Beneficial Owners (UBOs)
• Documentation supporting the nature of the business

Risk-Based Customer Due Diligence

ParlyPay applies a risk-based approach to customer due diligence.

Customers are assessed using multiple risk indicators, including but not limited to:

• Jurisdiction
• Nature of business
• Transaction activity
• Account behaviour
• Source of funds (where applicable)
• Beneficial ownership
• Fraud and security indicators

Where appropriate, ParlyPay may request additional information or documentation before approving an account or enabling certain services.

Enhanced Due Diligence (EDD)

Additional verification may be required where higher-risk circumstances are identified, including:

• High-risk jurisdictions
• Complex ownership structures
• Politically Exposed Persons (PEPs)
• Higher-value transactions
• Unusual account activity
• Adverse media findings

Depending on the circumstances, additional documentation may include proof of address, source of funds, source of wealth, business documentation, contracts, invoices, or other supporting information.

Ongoing Customer Due Diligence

Customer due diligence is an ongoing process. ParlyPay may periodically review customer information, refresh verification records, reassess customer risk profiles, and request updated documentation where necessary to comply with applicable legal and regulatory obligations.

Sanctions Screening

ParlyPay maintains a comprehensive sanctions screening programme designed to prevent prohibited persons, organisations, and jurisdictions from accessing our platform.

Screening is performed throughout the customer relationship, including during account onboarding, account updates, and, where appropriate, prior to the execution of certain transactions.

Screening may include:

• Applicable government sanctions lists
• Restricted party lists
• Politically Exposed Persons (PEP) databases
• Adverse media databases
• Internal fraud prevention databases

Where potential matches are identified, ParlyPay may:

• Delay or decline account approval
• Suspend or restrict transactions
• Request additional documentation
• Conduct further compliance reviews
• Take any action required under applicable laws and regulations

Transaction Monitoring

ParlyPay monitors customer activity to detect potential money laundering, terrorist financing, fraud, sanctions evasion, and other unlawful financial activity.

Our monitoring program combines automated technology with human oversight to identify unusual or potentially suspicious activity based on transaction patterns, customer risk profiles, account behaviour, and other relevant indicators.

Monitoring may consider factors such as:

• Transaction frequency
• Transaction value
• Geographic risk
• Customer behaviour
• Device and account security indicators
• Transaction consistency with expected account activity

Where appropriate, ParlyPay may:

• Request additional information or supporting documentation
• Delay or suspend transactions while reviews are conducted
• Apply enhanced due diligence measures
• Restrict account functionality
• Decline transactions that present unacceptable risk
• Report suspicious or reportable activity to the appropriate authorities where required by applicable law

Regulatory Reporting

ParlyPay maintains procedures to identify, investigate, document, and report financial activity where reporting obligations arise under applicable laws and regulations.

Where legally required, ParlyPay may submit reports relating to suspicious activity, reportable currency transactions, sanctions matters, or other regulatory reporting obligations to the appropriate governmental authorities.

To preserve the integrity of financial crime investigations, ParlyPay does not disclose whether regulatory reports have been filed or may be filed concerning any customer or transaction, except where required by law.

Recordkeeping

ParlyPay maintains records relating to:

• Customer identification and verification
• Account information
• Transaction history
• Compliance reviews
• Risk assessments
• Regulatory reporting
• Supporting documentation

Records are securely maintained for the periods required under applicable laws and regulations and are made available to competent regulatory or law enforcement authorities where legally required.

Governance and Compliance Oversight

ParlyPay’s compliance programme is supported by a governance framework that includes:

• Written compliance policies and procedures
• Designated compliance leadership
• Enterprise-wide financial crime risk assessments
• Internal controls
• Independent programme testing and reviews
• Periodic policy updates
• Ongoing employee compliance training
• Continuous monitoring and programme improvement

Our compliance framework is regularly reviewed to address evolving financial crime risks, technological developments, and changes in applicable legal and regulatory requirements.

Customer Responsibilities

Customers are expected to provide accurate, complete, and truthful information when using ParlyPay.

To support our legal and regulatory obligations, customers may be required to provide additional information or documentation during account opening, transaction reviews, or ongoing compliance monitoring.

Failure to provide requested information, or the provision of false, misleading, or fraudulent information, may result in:

• Delayed services
• Declined or suspended transactions
• Temporary account restrictions
• Account suspension or termination
• Other actions permitted under our Terms of Service and applicable law

Our Commitment

ParlyPay is committed to protecting customers, businesses, and the global financial ecosystem through responsible financial crime prevention. By combining advanced technology, risk-based compliance controls, ongoing due diligence, and strong governance, we strive to provide a secure, trusted, and transparent platform for cross-border payments, escrow services, and financial transactions while meeting our legal and regulatory obligations across the jurisdictions in which we operate.