11. Transaction Monitoring

Importapay monitors customer activity and transactions through a combination of behavior-based transaction monitoring for unusual and suspicious activity. This detects suspicious patterns such as structuring, high-risk jurisdiction exposure, unusual transaction velocity, and anomalous activity. Suspicious transactions will be reviewed by the compliance team for further investigation and, where

appropriate, escalation through the SAR filing process. Importapay will monitor customer activity across key transaction flows, including but not limited to: account funding, currency conversions (fiat-to-stablecoin and stablecoin-to-fiat), cross-border remittance transactions, and withdrawals. These flows are continuously reviewed to detect unusual or potentially suspicious patterns, with enhanced scrutiny applied to behaviors outside of expected customer profiles.

11.1 Suspicious Transaction Reporting Obligation

Importapay is committed to detecting, preventing, and reporting suspicious activities in line with applicable Anti-Money Laundering (AML) andCounter-Terrorist Financing (CTF) laws. As part of this obligation, Importapay maintains a robust framework for identifying and reporting Suspicious Transaction Reports (STRs) to the relevant Financial Intelligence Unit (FIU) across all jurisdictions of operation.

Where suspicion is confirmed, Importapay will file an STR with the appropriate FIU within the legally prescribed timelines. Reports will be accurate, complete, and include all relevant transaction details, customer information, and reasons for suspicion. Importapay ensures that STR filings are documented and securely retained in accordance with record-keeping requirements.

Following the filing of an STR, Importapay may apply enhanced monitoring, transaction restrictions, or account termination where necessary, subject to legal and regulatory requirements. Decisions are risk-based and documented accordingly.

11.2 Currency Transaction Reporting Obligation

Currency Transaction Reporting applies to transactions involving cash or cash-equivalent instruments that meet or exceed regulatory reporting thresholds within a single transaction or through multiple related transactions conducted within a defined period. These thresholds are determined by the applicable laws of the jurisdictions in which Importapay operates.

CTR requirements are threshold-based and mandatory, and reports must be filed

regardless of whether the transaction appears suspicious.

Transactions Subject to CTR

CTR obligations may apply to:

• Large cash deposits or withdrawals

• Multiple cash transactions structured to meet or exceed reporting thresholds

• Cash-equivalent transactions required by regulation.

Where Importapay does not directly handle physical cash, equivalent regulatory reporting obligations (where applicable) will be applied to transactions deemed functionally similar to cash by local regulators.

11.3 Suspicious Activity Reporting (SAR)

In the event that criminal activity by either customers or Company employees comes to the attention or suspicion of any Company employee, prompt reporting of the matter to the CCO is required. The CCO will initiate a timely investigation into the matter to assess whether it should be referred to the Regulator. This investigation will involve a thorough examination of the submitted facts by the employee and discussions with company officers responsible for the affected areas.

Should the circumstances warrant the matter being referred to the CCO, the compliance team will file an Unusual Activity Report (UAR) with the CCO. The determination of whether the UAR warrants the filing of a suspicious activity report with the Regulator will rest solely with the CCO.

To maintain confidentiality, the CCO and any other employee privy to the matter will ensure the information remains undisclosed. Furthermore, the Company will refrain from including the referral in the personnel files of any Company directors, officers, or employees who may be involved in the suspicious activity.