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Compliance

The PINPAY Network and the PINPAY SoftCard services are dedicated to full compliance with the laws and regulations which address anti-money laundering and online gambling. The following polices are in place to assure such compliance.

PINPAY and SoftCard Global Approach to Anti-Money Laundering

PINPAY and SoftCard ("PINPAY") has enterprise-wide policies covering Anti-Money Laundering, Client Due Diligence, Terrorist Financing and Economic Sanctions. These policies are designed to guide PINPAY and it's affiliated businesses in setting up their own policies, guidelines and processes to ensure compliance with USA's, Canada's, Australia's, United Kingdom's anti-money laundering laws and regulations and with various other anti-money laundering laws and regulations to which PINPAY operations are subject in other jurisdictions in which they operate.

These regulatory obligations cover the reporting of suspicious transactions, large cash transaction reporting, electronic funds transfer reporting, reporting of cross border movements of cash and monetary instruments, client identification and verification as well as terrorist financing reporting requirements.

PINPAY defines money laundering as any act or attempt to disguise the source of money or assets derived from criminal activity or terrorist activities which are designed with the objective of instigating terror or injury to individuals and/or property. Money laundering is a criminal offence in many jurisdictions in which PINPAY does business. PINPAY is committed to preventing the use of its payment and money transfer financial services for money-laundering purposes, by establishing policies and processes to ensure that:

(a) only those whose activities can reasonably be established to be legitimate are accepted as merchant, ISO, and cardholder clients,

(b) the automated processing system and the staff are trained to recognize and react appropriately to unusual or potential money-laundering activity and understand their legal obligations to report and attempt to block such activity and transactions, and

(c) appropriate records of client information and transactions are retained.

Each platform and business is required to assess its operations to identify potential money laundering risks and establish policies, procedures, guidelines and risk mitigation strategies, specific to its business and potential money laundering risk and in compliance with relevant laws, to implement these objectives.

PINPAY's operating policy requires that its businesses and affiliates identify reportable activities and transactions in each jurisdiction in which they operate and establish processes to ensure reporting as required. In addition, they are required to establish processes to identify and investigate unusual activities and transactions and ensure that all activities and transactions reasonably suspected to be related to money laundering are reported to the PINPAY Anti-Money Laundering Compliance Officer.

PINPAY businesses and affiliates are required to take reasonable and appropriate measures to establish the identities of their clients and others for whom they may provide payment and money transfer financial services, and to open accounts and conduct transactions only after identity is verified to PINPAY's satisfaction.

PINPAY policy requires businesses and affiliates to document the measures taken to identify clients and retain records of the due diligence measures taken for at least 5 years after the account in question is closed.

Anti-Terrorism and Know Your Client
In addition, PINPAY has developed enterprise-wide policies and procedures regarding compliance with economic sanctions and anti-terrorism legislation, as well as an enterprise-wide client due diligence policy. These policies also constitute minimum standards for the enterprise in these areas.

Audits
The PINPAY Anti-Money Laundering Compliance Officer reviews Anti-Money Laundering, Anti-Terrorism, Economic Sanctions and Client Due Diligence Programs for compliance with the relevant policies, procedures and regulations in all relevant audits completed during each audit cycle. In addition, from time to time the Compliance Officer conducts enterprise-wide audits specific to these areas.

Technological Tools
PINPAY has developed and implemented various solutions to assist in complying with monitoring and the reporting obligations including the development and rollout of an automated process which blocks activities of certain individuals and organizations, a suspicious activity monitoring and reporting system and a regulatory reporting system.

In addition, PINPAY has developed a client name scanning system that searches all client databases regularly against various control lists to ensure that PINPAY is not knowingly doing business with a listed individual or entity. As part of its effort to enhance its ability to identify suspicious transactions and activity, PINPAY has implemented a global money laundering transaction monitoring system that in real time continually reviews and blocks attempted illegal transactions.

Oversight
PINPAY has established a senior-level management position dedicated to the task of overseeing its global policies, practices and procedures with regard to anti-money laundering and anti-terrorist financing. In addition, the development of the many processing algorithms and programs is evidence of the commitment of senior management to the implementation of appropriate controls and compliance procedures across all PINPAY businesses and operations.

For further information, please contact:
Mr. John Stong
Compliance Officer, Anti-Money Laudering
ACAP Security Inc.
PINPAY Network
18700 Main Street, Ste 204A
Huntington Beach, CA, USA 92648
complianceteam@softcard.biz


PINPAY and SoftCard Global Approach to On-Line Gambling Restrictions

PINPAY and SoftCard ("PINPAY") has enterprise-wide policies covering compliance with On-Line Gambling Restrictions. These policies are designed to guide PINPAY and it's affiliated businesses in setting up their own policies, guidelines and processes to ensure compliance with USA's, Canada's and other country's anti-online gambing laws and regulations and with various other anti-online gambling laws and regulations to which PINPAY operations are subject in other jurisdictions in which they operate.

These regulatory obligations cover the blocking of electronic funds transfer from individuals to certain online gambling sites when the location source of the transfer is within a USA jurisdiction, including its possessions and territories, and other countries and jurisdictions who have notified PINPAY of their laws and regulations which limit or prohibit the transfer of funds to certain types of online gambling sites.

PINPAY defines prohibited online gambling money transfers as any actual or attempted money transfer from a computer or electronic device, including cell phones, or a point of sale terminal or facility located within a prohibited country, to a online merchant's site where such site is offering online gambling services known by PINPAY to be a gambling activity which is a prohibited activity under the source country's anti-online gambling laws and regulations. Online gambling is a criminal offence in some jurisdictions in which PINPAY does business. PINPAY is committed to preventing the use of its payment and money transfer financial services for illegal online gambling purposes, by establishing policies and processes to ensure that:

(a) only those whose activities are established to be in compliance with online gambling laws are accepted as merchant, ISO, and cardholder clients,

(b) the automated processing system and the staff are trained to recognize and react appropriately to actual or potential illegal online gambling activity and understand their legal obligations to report and attempt to block such activity and transactions, and

(c) appropriate records of client information and transactions are retained.

Each platform and business is required to assess its operations to identify potential online gambling compliance risks and establish policies, procedures, guidelines and risk mitigation strategies, specific to its business and potential online gambling compliance risk and in compliance with relevant laws, to implement these objectives.

PINPAY's operating policy requires that its businesses and affiliates identify reportable activities and transactions in each jurisdiction in which they operate and establish processes to ensure reporting as required. In addition, they are required to establish processes to identify and investigate unusual activities and transactions and ensure that all activities and transactions reasonably suspected to be related to illegal online gambling are reported to the PINPAY Online Gambling Compliance Officer.

PINPAY businesses and affiliates are required to take reasonable and appropriate measures to establish the identities of their clients and others for whom they may provide payment and money transfer financial services, and to open accounts and conduct transactions only after identity is verified to PINPAY's satisfaction.

PINPAY policy requires businesses and affiliates to document the measures taken to identify clients and retain records of the due diligence measures taken for at least 5 years after the account in question is closed.

Anti-Online Gambling and Know Your Client
In addition, PINPAY has developed enterprise-wide policies and procedures regarding compliance with anti-online gambling legislation, as well as an enterprise-wide client due diligence policy. These policies also constitute minimum standards for the enterprise in these areas.

Audits
The PINPAY Online Gambling Compliance Officer reviews Anti-Online Gambling and Client Due Diligence Programs for compliance with the relevant policies, procedures and regulations in all relevant audits completed during each audit cycle. In addition, from time to time the Compliance Officer conducts enterprise-wide audits specific to this areas.

Technological Tools
PINPAY has developed and implemented various solutions to assist in complying with monitoring and the reporting obligations including the development and rollout of an automated process which blocks activities of certain individuals and organizations, a suspicious activity monitoring and reporting system and a regulatory reporting system.

In addition, PINPAY has developed an Online Gambling monitoring system, which identifies actual and potential online gambling sites. Using this important informational database as the control list, PINPAY has established a merchant client name scanning system that searches all merchant client databases regularly against the PINPAY control lists to ensure that PINPAY is not knowingly allowing any client to transfer money to a online gambling site from a country which prohibits such money transfers. As part of its effort to enhance its ability to identify suspicious transactions and activity, PINPAY has implemented a global money transfer transaction monitoring system that in real time continually reviews and blocks attempted illegal transactions associated with illegal online gambling.

Oversight
PINPAY has established a senior-level management position dedicated to the task of overseeing its global policies, practices and procedures with regard to illegal online gambling money transfers. In addition, the development of the many processing algorithms and programs is evidence of the commitment of senior management to the implementation of appropriate controls and compliance procedures across all PINPAY businesses and operations.

For further information, please contact:
Mr. John Stong
Compliance Officer, Anti-Money Laudering
ACAP Security Inc.
PINPAY Network
18700 Main Street, Ste 204A
Huntington Beach, CA, USA 92648
complianceteam@softcard.biz