AML & CTF Policy

This Anti-Money Laundering and Counter-Terrorist Financing Policy (the "Policy") describes, at a high level, how wemopay.net ("Wemopay", "Platform", "we", "us") helps prevent and mitigate risks of money laundering, terrorist financing, fraud, and other financial crime.

This Policy is published for transparency and does not disclose internal detection rules, thresholds, or sensitive security controls.

Legal Entity (Policy Owner)

This Policy is issued by:

SPARKPAY SOLUTIONS INC. (Newfoundland and Labrador, Canada)

Company №: 01098 | Incorporated: 2025-02-07

Registered Office: 167A Elizabeth Ave, St. John's, NL, Canada, A1B 1S8

AML/Compliance contact: [email protected]

1) Purpose and Scope

Wemopay is committed to complying with applicable AML/CTF laws and regulatory expectations in the jurisdictions where our services are available. This Policy applies to:

  • merchant onboarding and account administration on Wemopay; and
  • activity associated with the use of the Platform, including transaction-related workflows and support interactions.

2) Core Principles

Wemopay's AML/CTF approach is built on:

  • a risk-based framework to assess and manage financial crime risk;
  • customer identification and due diligence before and during service provision;
  • ongoing monitoring to identify unusual or potentially suspicious activity;
  • recordkeeping in line with legal and regulatory requirements; and
  • cooperation with lawful requests from competent authorities where required.

3) Customer Identification and Due Diligence (KYC/CDD)

To protect the Platform and meet compliance obligations, Wemopay may request and verify information such as:

  • business identity and registration details;
  • ownership and control information (including beneficial ownership where applicable);
  • identity and authorization of representatives;
  • business activity, expected use of services, and supporting documentation where needed.

Enhanced due diligence may be applied in higher-risk situations, for example based on geography, industry, ownership structure, or other risk indicators.

4) Sanctions and Restricted Use

Wemopay takes measures intended to reduce the risk of use of the Platform in connection with sanctioned, prohibited, or unlawful activity. Where applicable, we may conduct checks against relevant sanctions or watchlists and restrict, suspend, or refuse service when required by law or to protect the Platform.

5) Monitoring and Suspicious Activity

Wemopay uses a combination of operational and technical controls to identify and respond to potentially suspicious activity. This may include:

  • automated and manual review of account behavior and transaction patterns;
  • investigation of anomalies, inconsistencies, and security signals;
  • escalation to compliance review where risk indicators are present.

Where legally required, Wemopay may submit reports to competent authorities and may take protective actions consistent with applicable law, including applying limitations to an account or suspending access.

6) Merchant and User Responsibilities

All Platform users are expected to:

  • provide accurate, complete, and up-to-date information during onboarding and thereafter;
  • use the Platform only for lawful purposes;
  • maintain appropriate internal controls and access security for their accounts;
  • promptly report suspected fraud, unauthorized access, or suspicious activity.

7) Governance, Training, and Review

Wemopay maintains internal governance measures to support AML/CTF compliance, which may include:

  • defined compliance responsibilities and oversight;
  • periodic training appropriate to employee roles;
  • ongoing review and updates to reflect evolving risks, product changes, and regulatory requirements.

8) Data Protection and Confidentiality

AML/CTF activities may involve processing personal data. Such processing is performed in accordance with Wemopay's Privacy & Data Protection Policy. Where required by law, Wemopay may share information with regulated partners and competent authorities.

9) Policy Updates

We may update this Policy from time to time to reflect changes in laws, regulatory expectations, or Platform operations. The current version will be published on wemopay.net with an updated effective date.

10) Contact

For AML/CTF compliance questions or to report suspicious activity, contact: [email protected].