UAB "Turbo pay" (trading name Payhof, here and after Payhof) is an Agent of Payswix, UAB that is authorized by the Central Bank of Lithuania (Nr. 21) for the issuing of electronic money.

This statement describes Joint Payhof and payswix AML Risk Appetite and provides the framework through which the Business describes the level and types of AML risk that Payhof is willing to incur in executing its broader business strategy.

Payhof is fully committed to comply with respective applicable regulations and industry best standards, and has implemented internal policies, procedures and detailed instructions to prevent itself from being used to facilitate money laundering, financing terrorism or engage in other unlawful activities such as bribery, fraud and corruption or tax evasion.

Accepted Business

As a general rule, Payhof does not onboard customers engaged in businesses or activities that are illegal, conducted in absence of required licenses or permissions, or present an excessive reputational risk for Payhof.

Unacceptable Levels of Risk.

Payhof will not knowingly conduct business with anyone who has engaged in any criminal activities. Further, Payhof will not enter into a business relationship with prohibited parties which include:

• Exact matches on Sanctions lists;
• Individual accounts for persons residing outside the European Economic Area except Switzerland, the United Kingdom and Ukraine;
• Shell Banks, and those providing services to Shell banks;
• Parties that are not transparent or unwilling to provide information;
• Bearer shares;
• Individuals deemed to be Politically Exposed Persons (PEPs);
• Entities with senior management and/or UBOs deemed to be Politically Exposed Persons;
• Trust or similar legal arrangements and Legal entities who have trust or similar legal arrangements in their ownership structure, unless the ownership percentage does not exceed 9.99%, the ownership structure is not overly complex without an argumentative and logical explanation, and the ownership structure may be found in public and independent sources;
• Customers where UBO(s), Board member (s) or any representative is a nominee, unless the ownership percentage does not exceed 9.99%, the ownership structure is not overly complex without an argumentative and logical explanation, and the ownership structure may be found in public and independent sources;
• Entities where UBO(s), Board Member (s), Supervisory Board Member (s), Director (s) are residents of prohibited jurisdiction stated Country Risks document which is under policies & procedures within internal server. Mentioned document is updated monthly or when necessary.

The MLRO will work with the senior management team and the Board to conduct a comprehensive review of all relevant customer information to determine the proper course of action.

AML Risk Limits

The MLRO has the responsibility to oversee all components of the AML Policy. It is the responsibility of the Board to ensure that there are appropriate and proportional systems and controls in place to mitigate the furtherance of financial crime. The MLRO may recommend restrictions on business activities, existing or prospective, and such restrictions will be reported to the Board stating the reasons for such action. Business clients risk depends on the type of industry and jurisdiction and risk of individuals based on country of residence.

Jurisdiction risk

Not acceptable Jurisdictions:

Afghanistan Algeria American Somoa Angola Anguilla Azerbaijan Bangladesh Barbados Belarus Burkina Faso Burundi Cambodia Cameroon Central African Republic Chad Comoros Congo	Cote d'Ivoire Crimea Croatia Democratic Republic of Congo DPRK Equatorial Guinea Eritea Fiji Guam Guatemala Guinea-Bissau Haiti Honduras Iran Iraq Jamaica Kazakhstan	Kenya Kyrgyzstan Laos Lebanon Liberia Libya Madagascar Mali Monaco Mozambique Myanmar Namibia Nepal Nicaragua Nigeria Pakistan Palau
Palestinian Territory Panama Paraguay Philippines Russia Samoa Senegal Somalia South Africa South Sudan Sudan Syria Tajikistan Tanzania Trinidad and Tobago Turkmenistan Uganda	US Virgin Islands Uzbekistan Vanuatu Venezuela Yemen Vietnam Zimbabwe

Industry risk

Declined Lines of Business Policy

You may not use Payhof services for the following activities:

• Violate any law, statute, ordinance or regulation;
• Unregulated/unlicensed Financial Institutions;
• Unregulated (or activity without registration) Virtual Asset Service Providers;
• Unregulated Forex or CFD;
• Unlicensed investment and financial services;
• Non-fungible token (NFT);
• Collection of donations as a charity or non-profit organization, NGO's (unregulated, unregistered, and incorporated outside EU);
• Unregulated pharmaceuticals, and or unlicensed drug related activity;
• Oil & Gas Industries (extraction, distribution);
• Activities relate to the sale of dangerous or hazardous goods;
• Replicas;
• Adult services - this includes, but is not limited to, pornography and nudity (webcam) streaming websites, escort;
• Unlicensed gambling, gaming, casino, betting, or related services;
• Customers engaging in alcohol and tobacco trade (including online sale);
• Weapons, firearms, and ammunitions (production, distribution);
• Customers engaged in drug sale such as marijuana or other illegal substances;
• Religious Organizations and NPOs;
• Extractive industries such as extraction of precious stones and minerals;
• Art and Antiques.

Payhof is accepting to establish new business relationship with prospective clients from the below sectors with specific requirements as listed below, whereby enhanced due diligence is applied in line with Payhof AML Policy and other internal procedures:

Business Activity	Regulation Status	Risk
Gambling, gaming, and casino	Regulated/Licensed	Auto-high
Virtual Currencies - Exchange	Regulated/Licensed	Auto-high
Sales, rental, and development of properties	N/A	Auto-high
Banking, insurance and regulated financial services	Regulated/Licensed	Auto-high
Investment	Regulated/Licensed	Auto-high
Forex trading/CFD regulated	Regulated/Licensed	Auto-high
Money exchange (MSB)	Regulated/Licensed	Auto-high
Activities related to gaming and gambling (agents, IT, marketing, referral, ..)	N/A	Auto-high