13. Record-Keeping Requirement

Importapay documents its verification procedures, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancy discovered in the identifying information.

Importapay keeps records containing a description of any document that it relied on to verify a customer's identity, noting the type of document, any identification number contained in the document, the place of issuance, and, if any, the date of issuance and expiration date. With respect to non-documentary verification, Importapay retains records that describe the methods and the results of any measures it took to verify the identity of a customer.

Records required to be retained may be made in the ordinary course of business.

Additionally, Importapay retains access to transactional records generated in the ordinary course of business that would be needed to reconstruct a customer's use of Importapay services to make transactions. Importapay retains all required records for a period of five (5) years or five (5) years from the date of account closure. Furthermore, the retained records are filed or stored in such a way as to be accessible within a reasonable period of time, taking into consideration the nature of the record and the amount of time elapsed since the record was made.

13.1 Record Retention Requirements

Generally, records relating to Importapay’s AML Program must be retained for a period of five (5) years from the date of the transaction. Failure to retain records is considered to be a record-keeping violation under the AML/CFT Regulations.

Importapay retains all necessary documents under all laws and regulations and is governed by its AML Program. Importapay maintains the following records in compliance with AML/CFT Regulations requirements:

• Copies of all filed STRs and the original or copies of any supporting documentation, are maintained for five (5) years from the date of filing the STR

• All records created for the Importapay AML Program requirements are retained for five (5) years

• Copies of records required for transmittals of funds are retained for five (5) years.

• Identifying information is obtained at account opening for five (5) years after the account is closed.