AML/KYC Policy

1. Commitment and Purpose

Orbit Technologies Ltd. ("Orbit", "we", "us", or "our") is firmly committed to preventing the use of its cryptocurrency-to-card platform for money laundering, terrorist financing, proliferation financing, and other financial crimes. We maintain a comprehensive Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program designed to detect, prevent, and report suspicious activities in accordance with all applicable laws and regulations.

This policy applies to all Orbit employees, officers, directors, contractors, and agents, as well as to all users and transactions processed through the Orbit platform.

2. Regulatory Framework

Orbit's AML/CTF program is designed to comply with applicable laws and regulations across the jurisdictions in which we operate, including but not limited to:

• Financial Action Task Force (FATF) Recommendations and Guidance on Virtual Assets and Virtual Asset Service Providers (VASPs)
• European Union Anti-Money Laundering Directives (AMLD5/AMLD6) and the Markets in Crypto-Assets Regulation (MiCA)
• United Kingdom Money Laundering, Terrorist Financing and Transfer of Funds Regulations (MLR 2017, as amended)
• United States Bank Secrecy Act (BSA), USA PATRIOT Act, and FinCEN regulations
• Applicable local laws and regulations in all jurisdictions where Orbit provides services

Where regulatory requirements differ across jurisdictions, Orbit applies the most stringent applicable standard.

3. Customer Due Diligence (CDD)

Orbit implements a risk-based, tiered approach to customer due diligence to verify the identity of all users before granting access to our services. Our CDD procedures include:

3.1 Tier 1: Basic Verification

• Email address verification
• Phone number verification
• Full legal name and date of birth
• Country of residence
• Access limited to basic platform features with low transaction limits

3.2 Tier 2: Standard Verification

• Government-issued photo identification (passport, national ID card, or driver's license)
• Document authenticity verification through automated and manual review
• Facial recognition or biometric matching against submitted ID
• Proof of residential address (utility bill, bank statement, or government correspondence dated within the last 3 months)
• Access to standard transaction limits

3.3 Tier 3: Enhanced Verification

• Source of funds documentation (pay stubs, tax returns, bank statements, or investment records)
• Source of wealth documentation where required
• Additional identification or supplementary documents as determined by risk assessment
• Video verification call in certain cases
• Access to the highest transaction limits

Orbit will not establish or maintain a business relationship with any individual or entity whose identity cannot be adequately verified. We reserve the right to request additional documentation at any time to maintain compliance.

4. Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied to higher-risk customers, relationships, and transactions. EDD is triggered by factors including, but not limited to:

• Customers identified as Politically Exposed Persons (PEPs) or their family members and close associates
• Customers residing in or conducting transactions involving high-risk jurisdictions as identified by the FATF or Orbit's own risk assessment
• Complex or unusually large transactions that have no apparent economic or lawful purpose
• Customers with adverse media findings or negative screening results
• Business relationships that present a higher risk of money laundering or terrorist financing based on Orbit's risk assessment methodology
• Transactions involving privacy coins, mixing services, or other tools designed to obscure transaction origins

EDD measures may include more frequent monitoring, additional documentation requirements, senior management approval for onboarding or continued service, and reduced transaction limits until satisfactory verification is completed.

5. Ongoing Monitoring

Orbit employs automated transaction monitoring systems to continuously analyze customer activity and detect potentially suspicious patterns. Our monitoring program includes:

• Real-time transaction screening against predefined rules and thresholds
• Pattern detection algorithms for structuring (smurfing), layering, and other common money laundering typologies
• Monitoring for rapid or unusually frequent cryptocurrency-to-fiat conversions
• Detection of transactions involving high-risk wallet addresses or darknet-linked addresses using blockchain analytics tools
• Monitoring for sudden changes in transaction patterns, volume, or behavior inconsistent with the customer's profile
• Periodic review and updating of customer risk profiles
• Cross-referencing customer data against updated sanctions lists, PEP databases, and adverse media sources

Flagged transactions and alerts are escalated to our dedicated compliance team for investigation and, where warranted, reporting to the appropriate authorities.

6. Suspicious Activity Reporting

Orbit is committed to identifying and reporting suspicious activity in accordance with applicable laws. When our compliance team determines that a transaction or series of transactions is suspicious, we will:

• File Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with the relevant Financial Intelligence Unit (FIU) or regulatory authority within the legally required timeframe
• Ensure all reports contain complete and accurate information about the suspicious activity, including the basis for suspicion
• Maintain strict confidentiality regarding the filing of reports (tipping-off is prohibited)
• Retain records of all filed reports and supporting documentation
• Suspend or restrict the relevant account or transaction pending further investigation, as appropriate

Employees are trained to recognize red flags and are required to report any suspicions of money laundering or terrorist financing to the designated Compliance Officer immediately.

7. Sanctions Screening

Orbit screens all customers, transactions, and counterparties against international sanctions lists to ensure compliance with applicable sanctions regimes. Our screening program covers:

• OFAC: U.S. Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List (SDN List) and other OFAC sanctions programs
• EU Sanctions: European Union Consolidated List of persons, groups, and entities subject to EU financial sanctions
• UN Sanctions: United Nations Security Council Consolidated List
• UK Sanctions: His Majesty's Treasury (HMT) Financial Sanctions List
• Other Jurisdictions: Additional sanctions lists applicable to the jurisdictions in which Orbit operates

Screening is performed at the point of customer onboarding, on an ongoing basis, and whenever sanctions lists are updated. Orbit does not provide services to individuals, entities, or jurisdictions subject to comprehensive sanctions. Any matches are immediately escalated and, if confirmed, result in the blocking of the account or transaction and reporting to the appropriate authorities.

8. Politically Exposed Persons (PEP) Screening

Orbit screens all customers against PEP databases at the time of onboarding and on an ongoing basis. A PEP is defined as an individual who holds, or has held within the past 12 months, a prominent public function, including but not limited to: heads of state, senior government officials, senior judicial or military officials, senior executives of state-owned enterprises, and senior political party officials.

Family members and known close associates of PEPs are also subject to enhanced screening. Identified PEPs and their associates are subject to Enhanced Due Diligence measures, including senior management approval for the business relationship, enhanced ongoing monitoring, and source of funds and source of wealth verification.

9. Record Keeping

Orbit maintains comprehensive records of all customer due diligence activities, transactions, and compliance actions. Our record-keeping practices include:

• Customer identification and verification records, including copies of all documents obtained during the CDD and EDD processes
• Complete transaction records, including dates, amounts, currencies, cryptocurrency wallet addresses, and counterparty information
• Records of all sanctions and PEP screening results
• Documentation of suspicious activity investigations and SAR/STR filings
• Risk assessments and risk profile updates
• AML/CTF training records for all employees
• Correspondence with regulatory authorities and law enforcement

All records are retained for a minimum of five (5) years from the date of the transaction or the end of the business relationship, whichever is later, or for such longer period as may be required by applicable law. Records are stored securely with appropriate access controls.

10. Employee Training

Orbit provides mandatory AML/CTF training to all employees upon onboarding and on a recurring basis (at least annually). Training covers:

• Overview of applicable AML/CTF laws, regulations, and FATF standards
• Orbit's AML/CTF policies, procedures, and internal controls
• Customer due diligence requirements and procedures, including identifying and verifying customers
• Recognition of red flags and indicators of suspicious activity, with a focus on cryptocurrency-specific typologies
• Sanctions compliance, PEP identification, and escalation procedures
• Reporting obligations, including internal escalation and external filing of SARs/STRs
• Consequences of non-compliance, including criminal and civil penalties

Additional specialized training is provided to compliance team members, senior management, and other employees in roles with direct AML/CTF responsibilities.

11. Risk Assessment

Orbit conducts a comprehensive AML/CTF risk assessment on a regular basis (at least annually) and whenever there are material changes to our business, products, customer base, or the regulatory environment. Our risk assessment methodology considers:

• Customer Risk: Customer type (individual or entity), geographic location, occupation, transaction patterns, PEP status, and adverse media findings
• Product/Service Risk: Risks associated with specific products and services, including cryptocurrency conversion, virtual cards, physical cards, and cross-border transactions
• Geographic Risk: Country risk ratings based on FATF assessments, Transparency International Corruption Perceptions Index, and other relevant indicators
• Channel Risk: Risks associated with service delivery channels, including online and mobile platforms
• Cryptocurrency-Specific Risk: Risks unique to cryptocurrency, including privacy coins, peer- to-peer exchanges, unhosted wallets, and mixing or tumbling services

The results of the risk assessment inform the design and calibration of our AML/CTF controls, monitoring rules, and resource allocation.

12. Cooperation with Law Enforcement

Orbit cooperates fully with law enforcement agencies and regulatory authorities in the investigation and prosecution of financial crimes. This includes:

• Responding to lawful requests for information, including subpoenas, court orders, and regulatory inquiries
• Providing transaction records, customer information, and other relevant data as required by law
• Freezing or blocking accounts and funds as directed by applicable authorities or sanctions requirements
• Participating in information-sharing arrangements with other financial institutions and VASPs, where permitted by law, to combat financial crime

Orbit's designated Compliance Officer serves as the primary point of contact for all communications with law enforcement and regulatory authorities.

13. Penalties for Non-Compliance

Orbit takes compliance with AML/CTF requirements seriously. Non-compliance by users or employees may result in:

• For Users: Immediate suspension or termination of account and services, freezing of funds, reporting to law enforcement and regulatory authorities, and potential civil or criminal prosecution
• For Employees: Disciplinary action up to and including termination of employment, and potential personal criminal and civil liability under applicable law

Orbit may also be subject to regulatory penalties, fines, and enforcement actions for failures in its AML/CTF program. We are committed to continuous improvement of our compliance program to mitigate these risks.

14. Contact Information

If you have questions about this AML/KYC Policy, or if you wish to report suspicious activity, please contact our Compliance team:

• Email: [email protected]
• Company: Orbit Technologies Ltd.
• Address: 10, Harshal Heights, Pimpri Chinchwad Link Road, Chinchwad, Pune - 411 033, India
• Website: paywithorbit.com