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AML & Sanctions Policy

Effective Date: March 2026

Ross Payments Corp. ("Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We strictly adhere to the Bank Secrecy Act (BSA), regulations promulgated by the Financial Crimes Enforcement Network (FinCEN), and the most recent March 2026 U.S. Securities and Exchange Commission (SEC) frameworks governing stablecoins and digital asset settlement for B2B transactions.

1. Know Your Business (KYB) & Customer Identification Program (CIP)

We are required by federal law to obtain, verify, and record information that identifies each entity that opens an account. When you open a Ross Payments account, we will ask for your company's legal name, formation documents, Employer Identification Number (EIN), and the identities of Ultimate Beneficial Owners (UBOs) holding 25% or more equity.

2. OFAC Sanctions Screening

Before processing any cross-border transaction or establishing a business relationship, we utilize automated screening tools against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list. We prohibit the use of our platform by individuals or entities located in comprehensively sanctioned jurisdictions (e.g., Iran, North Korea, Syria, Cuba, Russia).

3. Ongoing Monitoring and Suspicious Activity Reporting (SAR)

Our platform employs transaction monitoring heuristics to detect unusual patterns, velocity, or unverified supplier payouts. Any transaction flagged as suspicious will be held for manual compliance review. If the activity is deemed potentially illicit, we are obligated to file a Suspicious Activity Report (SAR) with FinCEN. We operate under a strict "no tipping off" policy.

4. Stablecoin Provenance and Travel Rule Compliance

All fiat-to-stablecoin and stablecoin-to-fiat conversions are routed through licensed, regulated U.S. Trust Companies (e.g., Circle Internet Financial, LLC) to ensure full compliance with the FATF Travel Rule. We track the origin and destination of all digital asset flows.

5. Compliance Contact

For compliance audits, subpoenas, or law enforcement inquiries, please contact our Chief Compliance Officer:
Email: alex.sterling@rosspayments.com
Address: Ross Payments Corp., 8 The Green STE A Dover, DE, USA 19901