2. Scope

This policy serves as a global Anti–Money Laundering and Countering-Terrorist Financing compliance framework for Importapay. It establishes the minimum global standards for the prevention of money laundering, terrorist financing, sanctions violations, and other financial crimes across all jurisdictions where Importapay operates or intends to operate.

This Policy applies to:

• Importapay’s operations globally

• All directors, officers, employees, contractors, and agents

• All products and services, including fiat, digital assets, and stablecoin-enabled transactions

The Policy is designed to comply with applicable AML/CTF laws and regulations in:

• Nigeria (CBN, NFIU, AML/CFT Regulations)

• United Kingdom (UK Money Laundering Regulations, FCA guidance,

POCA)

• Canada (FINTRAC requirements applicable to Foreign Money Services Businesses – FMSB)