UAB Montify LT (trading name Payhof, here and after Payhof) is an Agent of UAB GlobalNetint (GNI) that is authorized by the Central Bank of Lithuania (Nr. 21) for the issuing of electronic money.

This statement describes Joint Payhof and GNI 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.

AML Risk Profile

Payhof AML Risk Profile is composed of products and services, customers (individuals and entities) and country risk. Within these risk categories and as a result of the global reach in providing a service Payhof could be unwittingly used for the furtherance of financial crime. Financial crime – Payhof must comply with legal requirements to deter and detect financial crime, which includes money laundering and terrorist financing.

Products and services. Payhof focuses on B2B services offering e-wallet and bank wire options (SEPA/SWIFT). In Q4 Payhof will be offering debit cards linked to IBAN and card processing via partners that are incorporated and regulated in the EU. The highest risk is Transaction risk with particular attributes, which include, but are not limited to:

1. Transaction type.

- Could the type of transaction be used for the purposes of money laundering or is it at a higher risk of money laundering? (e.g., Salary - low risk, Estate Agency - higher risk);
- Does the transaction make sense or is it overly complex given the underlying nature of the business being
conducted?
- Does it make sense that your client has asked your firm to carry out this type of transaction? (e.g. is it
within your area of expertise/local geographical area?)

2. Value of transaction.

- Does the value of the transaction appear to fall within the financial means of the client, given their income and savings?

3. Source of funds.

- Is the source of funds clear and identifiable?
- Are funds coming from a recognized (regulated) financial/credit institution or are they personal funds?
- Is any funding coming from overseas? Where from? Who from? Connection to the client?
- Are any of the funds being paid by a third party otherwise unconnected to the transaction?

4. Destination of funds.

- Does transactional behaviour match money flow declared by the client?
- Any indications that account is used as transit?

5. Purpose of relationship.

- For what purposes customer use Payhof products?
- Is the account used for: operational purposes, settlement, trading etc?

Customers. Risks from Payhof‘s own customer base, their type of business or the ultimate beneficiary of funds needs to be considered when Payhof enters and conducts business. Payhof is using third-party provider „Acuity“ to conduct PEP’s and Sanctions screening.

Customers are divided into two categories: Individuals and Entities. The risk level of Individual clients will be determined by the country of residence.

The risk level of the Entity will be determined by their type of business, Age of legal entity, group structure complexity and beneficial owners, directors, and Authorised signatories risk.

Geography (Country) risk. Identifying geographic locations that may pose a higher risk is a core component of any inherent risk assessment and the business line will seek to understand and evaluate the specific risks associated with doing business in, opening and servicing accounts, offering products and services and/or facilitating transactions involving certain geographic locations.

Geography/Country risk may also be considered together with some of the other risk factors in other risk categories, for example, in Clients for FIs, and in Products and Services for Transactions. For example, the percentage of a business division, unit or business line’s transactions with a high-risk country may provide an indication of the inherent risk from a Geography/Country perspective.

Monitoring.

An element of a Payhof AML Policy in which client activity is reviewed for unusual or suspicious patterns, trends or outlying transactions that do not fit a normal pattern. Transactions are often monitored using software that weighs the activity against a threshold of what is deemed “normal and expected” for any given client. Payhof will rely on internal anti-money laundering system and controls. Monitoring is done automatically and manually by receiving alerts generated by the internal rules-based monitoring system.

Internal controls.

Policies, procedures, systems and personnel within Payhof, are structured to protect against the materialisation of a ML risk, or to ensure that risk factors are promptly identified.

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
• Foreign Shell Banks
• Unregistered Money Service Businesses (“MSBs”)
• Parties that are not transparent
• Bearer shares

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 risk of individuals based on country of residence.

Jurisdiction risk

Not acceptable Jurisdictions:

High risk Jurisdictions:

Albania Cote d'Ivoire Madeira Saint Lucia Algeria Curacao Maldives Saint Vincent and the Grenadines Angola Djibouti Marshall Islands Sark, Alderney Antigua & Barbuda Dominica Mauritius Seychelles Argentina East Timor Mongolia Senegal Armenia Ecuador Morocco Sint Maarten Bahrain Gaza Strip

Mozambique St Pierre & Miquelon Bangladesh Gibraltar Nauru Tahiti Barbados Guatemala Netherlands Antilles Tajikistan Belize Guernsey New Caledonia Tanzania Benin Holy See (Vatican) Nicaragua Thailand Bolivia Island of Saint Helen Nigeria Timor-Leste Brazil Isle of Man Niue

Ukraine British Virgin Is. Jersey Panama United Arab Emirates Cayman Islands Kazakhstan Palau Uruguay China Kenya Papua New Guinea Vanuatu Colombia Kosovo Paraguay Vietnam Comoros Latvia Philippines Cook Islands Liberia Puerto Rico Costa Rica Macau Saint Kitts & Nevis