Anti-Money Laundering Policy

NumsGo LLC ("Company," "we," "us," or "our") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We take our obligation to detect and prevent money laundering, terrorist financing, and other financial crimes seriously.

This AML Policy outlines the principles, procedures, and controls that we have implemented to ensure compliance with applicable laws and regulations. All employees, contractors, and agents of NumsGo LLC are required to adhere to this policy. Failure to comply may result in disciplinary action, including termination of employment, and may expose both the individual and the Company to criminal and civil liability.

Our AML program is designed to comply with applicable anti-money laundering laws and regulations, including but not limited to:

• The Bank Secrecy Act (BSA) of 1970 and its implementing regulations.
• The USA PATRIOT Act of 2001, including its enhanced due diligence requirements.
• Financial Crimes Enforcement Network (FinCEN) regulations and guidance.
• Office of Foreign Assets Control (OFAC) sanctions programs.
• The Anti-Money Laundering Act of 2020 (AMLA).
• Applicable state-level money transmission laws and regulations.
• International standards set by the Financial Action Task Force (FATF) where applicable.

We continuously monitor changes in AML/CTF legislation and update our policies and procedures accordingly to maintain compliance.

We implement a risk-based approach to Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures to verify the identity of our users and assess potential risks. Our KYC program includes:

3.1 Basic Due Diligence

For all users, we collect and verify the following information upon account registration:

• Full legal name
• Email address (verified through confirmation)
• IP address and geolocation data
• Payment method details

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied to higher-risk users, including those who:

• Exceed specified transaction volume thresholds.
• Operate from or have connections to high-risk jurisdictions as identified by FATF.
• Are identified as Politically Exposed Persons (PEPs) or their associates.
• Exhibit unusual transaction patterns or behavior that triggers risk indicators.

EDD may include requests for government-issued identification documents, proof of address, source of funds documentation, and additional verification steps. We reserve the right to restrict or suspend accounts pending successful completion of EDD procedures.

We maintain ongoing transaction monitoring systems designed to detect and flag potentially suspicious activities. Our monitoring program includes:

• Automated Monitoring: Automated systems analyze transactions in real-time to identify patterns that may indicate money laundering, terrorist financing, or other illicit activities. These systems flag transactions based on predefined rules and risk indicators.
• Volume Thresholds: Transactions that exceed certain volume or frequency thresholds are automatically flagged for manual review.
• Behavioral Analysis: We monitor for unusual account behavior, including rapid deposits and withdrawals, transactions inconsistent with the user's profile, and structuring patterns designed to avoid reporting thresholds.
• Manual Review: Flagged transactions are reviewed by trained compliance personnel who assess whether further investigation or reporting is required.

When suspicious activity is identified, we follow established procedures for investigation and reporting:

• Suspicious activities are escalated to our Compliance Officer for investigation and determination.
• Where required by law, we file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) within the required timeframes.
• We maintain detailed records of all investigations, including those that do not result in a SAR filing.
• We do not inform the user that a SAR has been or will be filed (as prohibited by law).
• Accounts associated with confirmed suspicious activity may be frozen, restricted, or terminated.

We maintain comprehensive records in compliance with applicable laws and regulations. Our record-keeping practices include:

• Customer Records: All KYC documentation, identity verification records, and customer correspondence are retained for a minimum of five (5) years after the account is closed or the business relationship ends.
• Transaction Records: All transaction records, including deposits, purchases, refunds, and wallet activity, are retained for a minimum of five (5) years from the date of the transaction.
• SAR Records: All records related to Suspicious Activity Reports, including supporting documentation and investigation notes, are retained for a minimum of five (5) years from the date of filing.
• Training Records: Records of AML/CTF training provided to employees, including dates, content, and attendance, are retained for the duration of employment and for three (3) years thereafter.

We maintain a comprehensive AML/CTF training program to ensure that all relevant personnel are equipped to identify and respond to potential money laundering and terrorist financing activities:

• All new employees receive AML/CTF training as part of their onboarding process.
• Annual refresher training is provided to all employees with customer-facing or compliance-related responsibilities.
• Training covers the recognition of red flags, reporting procedures, legal obligations, and the consequences of non-compliance.
• Specialized training is provided to compliance personnel on investigation techniques, SAR filing, and regulatory updates.
• Training materials are updated regularly to reflect changes in laws, regulations, and industry best practices.

We maintain a sanctions compliance program to ensure that we do not conduct business with sanctioned individuals, entities, or jurisdictions:

• All users are screened against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) and other applicable sanctions lists at the time of account creation and on an ongoing basis.
• Transactions involving sanctioned jurisdictions are blocked in accordance with applicable sanctions programs.
• We monitor updates to sanctions lists and re-screen our user base when lists are updated.
• Any matches or potential matches are escalated to our Compliance Officer for investigation and, if confirmed, are blocked and reported to the appropriate authorities.

We conduct periodic risk assessments to identify, evaluate, and mitigate money laundering and terrorist financing risks associated with our business. Our risk assessment considers:

• Customer Risk: The types of customers we serve, their geographic locations, and the nature of their business activities.
• Product/Service Risk: The inherent risks associated with virtual phone numbers and SMS verification services, including the potential for misuse.
• Geographic Risk: The jurisdictions in which we operate and from which our customers access the Service, with particular attention to high-risk and non-cooperative jurisdictions identified by FATF.
• Channel Risk: The risks associated with our online delivery channels, including the anonymity of internet-based transactions.
• Emerging Risks: New and evolving risks related to changes in technology, criminal methodologies, and the regulatory landscape.

Risk assessments are conducted at least annually and are updated as needed in response to significant changes in our business, customer base, or risk environment. The results of risk assessments inform our AML program, including the allocation of resources, the calibration of monitoring systems, and the application of enhanced due diligence measures.