Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Introduction

Bankario LC ("Bankario," "we," "our," or "us") is committed to maintaining a secure financial ecosystem and preventing the misuse of its Platform for money laundering, terrorist financing, fraud, sanctions evasion, corruption, or other financial crimes.

This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy describes the measures implemented by Bankario and its regulated financial partners to comply with applicable legal and regulatory requirements and to protect the integrity of the financial system.

Bankario reserves the right to update this Policy at any time to reflect changes in applicable laws, regulatory guidance, industry standards, or our risk management framework.

2. Scope

This Policy applies to: all individual customers; business customers; beneficial owners; directors and officers; authorized representatives; merchants; API users; partners using the Bankario Platform.

Compliance with this Policy is a condition of using the Platform.

3. Our Compliance Commitment

Bankario is committed to:

• preventing money laundering and terrorist financing;
• complying with applicable AML and sanctions laws;
• maintaining effective risk management procedures;
• implementing customer due diligence measures;
• monitoring transactions for suspicious activity;
• cooperating with competent authorities where legally required;
• protecting the integrity of the financial system.

4. Customer Identification Program (KYC)

Before certain Services become available, customers may be required to successfully complete identity verification.

Verification requirements vary depending on:

• country of residence;
• legal entity type;
• requested products;
• transaction activity;
• applicable regulations;
• assessed risk.

Verification may include one or more of the following:

• full legal name;
• residential address;
• date of birth;
• nationality;
• government-issued identification;
• passport;
• driver's license;
• proof of address;
• selfie verification;
• liveness detection;
• tax information;
• contact information.

Additional verification may be requested at any time.

Failure to provide requested information may result in delayed onboarding, restricted functionality, suspension, or account closure.

5. Business Verification (KYB)

Business customers may be required to provide information including:

• legal entity name;
• registration number;
• incorporation documents;
• registered address;
• tax identification number;
• ownership structure;
• directors and officers;
• authorized representatives;
• Ultimate Beneficial Owners (UBOs);
• operating jurisdictions;
• nature of business;
• expected transaction activity.

Bankario may request additional documentation where necessary.

6. Customer Due Diligence (CDD)

Customer Due Diligence is conducted to understand the identity and risk profile of customers.

CDD measures may include:

• identity verification;
• ownership verification;
• business activity review;
• sanctions screening;
• politically exposed person (PEP) screening;
• adverse media screening;
• expected account activity assessment;
• ongoing monitoring.

The level of due diligence applied depends on the customer's assessed risk.

7. Enhanced Due Diligence (EDD)

Additional verification may be required for higher-risk customers or activities.

EDD measures may include:

• source of funds verification;
• source of wealth verification;
• additional identity documentation;
• enhanced business documentation;
• transaction explanations;
• additional sanctions screening;
• senior compliance review.

EDD may also be applied to customers identified as:

• Politically Exposed Persons (PEPs);
• family members or close associates of PEPs;
• customers operating in higher-risk jurisdictions;
• customers engaged in higher-risk industries.

8. Ongoing Monitoring

Bankario and its regulated financial partners may conduct ongoing monitoring throughout the customer relationship.

Monitoring may include:

• transaction analysis;
• behavioral monitoring;
• unusual activity detection;
• changes in customer information;
• sanctions updates;
• adverse media monitoring;
• account risk reassessment.

Customers may be asked to update previously submitted information periodically.

9. Transaction Monitoring

Transactions may be reviewed using automated and manual processes.

Monitoring may identify:

• unusually large transactions;
• rapid movement of funds;
• unusual transaction patterns;
• inconsistent account behavior;
• suspected structuring;
• fraud indicators;
• sanctioned counterparties;
• blockchain risk indicators.

Monitoring does not guarantee that all suspicious activity will be detected.

10. Source of Funds & Source of Wealth

Bankario may request documentation demonstrating the origin of funds or wealth used in connection with the Platform.

Examples include:

• employment income;
• business revenue;
• investment proceeds;
• inheritance;
• property sales;
• savings;
• other lawful sources.

Failure to provide satisfactory documentation may result in restrictions on the account.

11. Sanctions Compliance

Bankario maintains sanctions compliance procedures designed to comply with applicable laws.

Customers, businesses, counterparties, and transactions may be screened against sanctions lists maintained by governmental or international authorities.

Bankario reserves the right to suspend or reject transactions involving sanctioned persons, entities, jurisdictions, or activities.

Additional information is available in our Sanctions Policy.

12. Prohibited Activities

The Platform may not be used for activities including, but not limited to:

• money laundering;
• terrorist financing;
• fraud;
• identity theft;
• sanctions evasion;
• tax evasion;
• bribery or corruption;
• ransomware payments;
• human trafficking;
• child exploitation;
• proliferation financing;
• financing illegal goods or services;
• deceptive financial practices.

Attempting to circumvent compliance controls is prohibited.

13. Regulatory Reporting

Where required by applicable law, Bankario and/or its regulated financial partners may report suspicious activity to competent authorities without prior notice to the customer.

Applicable laws may prohibit disclosure of such reports.

14. Requests for Additional Information

To comply with legal or regulatory obligations, Bankario may request additional documentation at any time.

Examples include:

• updated identification;
• proof of address;
• business documents;
• invoices;
• contracts;
• bank statements;
• transaction explanations;
• tax documentation;
• source of funds evidence.

Failure to respond within a reasonable timeframe may result in service restrictions.

15. Account Restrictions

Bankario reserves the right to:

• delay onboarding;
• reject applications;
• refuse transactions;
• impose transaction limits;
• suspend access;
• freeze functionality where legally required;
• terminate customer relationships.

Such actions may be taken where required by law, regulation, contractual obligations with financial partners, or our internal risk management procedures.

16. Record Retention

Bankario may retain customer identification, verification, transaction, and compliance records for the period required by applicable laws and regulatory obligations.

Certain records may be retained after account closure where legally required.

17. Cooperation with Authorities

Bankario may cooperate with law enforcement agencies, regulators, courts, and other competent authorities where required by applicable law.

Information may be disclosed in response to lawful requests or legal obligations.

18. Changes to this Policy

Bankario may amend this Policy from time to time.

Material updates will be published on the Platform and become effective upon publication unless otherwise stated.