AML & Compliance Policy

1. Policy Statement

**ZuraPay** (a product of **Zurafin Technologies Limited**) operates in strict compliance with international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws. We maintain a zero-tolerance policy for money laundering, terrorist financing, fraud, and other financial crimes. Our compliance program is designed to prevent our systems from being used for illicit activities.

2. Customer Due Diligence (CDD) & KYC

We implement a risk-based approach to Know Your Customer (KYC). Our identity verification levels include:

• Tier 1 (Basic): Verification of phone number and email address. Limited transaction limits.
• Tier 2 (Verified): Verification of government-issued ID (Passport, National ID) and facial biometrics. Higher limits enabled.
• Tier 3 (Enhanced): Proof of address and additional background checks for high-volume merchants or Politically Exposed Persons (PEPs).

3. Sanctions Screening

ZuraPay screens all users and transactions against global sanctions lists, including but not limited to:

• UN Security Council Consolidated List
• US Office of Foreign Assets Control (OFAC) Specially Designated Nationals List
• EU Consolidated List of Sanctions
• UK HM Treasury Sanctions List

We do not provide services to individuals or entities on these lists or located in sanctioned jurisdictions.

4. Transaction Monitoring & Reporting

We utilize automated systems to monitor transactions in real-time for suspicious patterns, such as structuring (smurfing), unusual velocity, or high-risk jurisdictions. Suspicious activities are investigated by our Compliance Team and reported to the relevant Financial Intelligence Unit (FIU) as required by law.

5. Record Keeping

We maintain records of all identification data obtained through the CDD process and all transaction data for a minimum period of five (5) years as mandated by regulatory standards.