Purpose & Scope

EIDDI Solutions LLC ("EIDDI") is committed to conducting business only with clients whose funds originate from legitimate sources and whose business activities are lawful. This Anti-Money Laundering (AML) Policy establishes EIDDI's voluntary framework for detecting and preventing involvement in money laundering, terrorist financing or other financial crimes, and for cooperating with lawful requests from authorities and financial institutions.

This policy applies to all engagements entered into with EIDDI Solutions LLC, all payment transactions processed through our payment infrastructure, and all employees, contractors and agents acting on behalf of EIDDI.

Know Your Customer (KYC)

EIDDI implements a risk-based client identification and verification programme before entering into service agreements. For standard business engagements, this involves:

• Verification of the client's business name, registered address and jurisdiction of incorporation
• Identification of the beneficial owner(s) of the client entity (individuals owning 25% or more)
• Confirmation of the intended use of services and the nature of the client's business
• Screening against OFAC Specially Designated Nationals (SDN) lists and other sanctions databases

For higher-risk engagements — defined by transaction size, geographic risk, client type or payment method — EIDDI may request additional documentation including government-issued ID, articles of incorporation, proof of business address or bank statements confirming source of funds.

EIDDI reserves the right to decline any engagement where KYC requirements cannot be satisfactorily completed.

Prohibited Clients & Transactions

EIDDI will not knowingly enter into service agreements or accept payments from:

• Individuals or entities listed on the OFAC SDN list or subject to US economic sanctions
• Entities operating in OFAC-sanctioned countries or regions
• Individuals or entities under investigation for, or convicted of, financial crimes, fraud or money laundering
• Shell companies with no identifiable beneficial owner and no clear legitimate business purpose
• Any person or entity whose funds EIDDI has reason to believe derive from illegal activity
• Anonymous clients — all clients must be identifiable prior to engagement

Accepted Payment Methods & Controls

EIDDI accepts payment exclusively through regulated, traceable payment channels:

• Payoneer — payments processed through Payoneer's regulated infrastructure, subject to Payoneer's own KYC and AML controls
• Wise — payments processed through Wise's regulated infrastructure, subject to Wise's own AML programme and transaction monitoring
• Bank Wire Transfer — wire payments processed through the regulated banking system, subject to standard banking AML controls

EIDDI does not accept cash payments, cryptocurrency, money orders, prepaid cards, third-party payments (payment from a party other than the contracting client) or payments through unlicensed money transfer services. Any attempt to pay through an unaccepted method will result in the transaction being declined and the engagement reviewed.

Transaction Monitoring & Red Flags

EIDDI monitors transactions for indicators of potentially suspicious activity. Red flags that may trigger enhanced review, declining or terminating an engagement, or referral to the relevant payment platform or authorities include:

• Payments significantly exceeding the agreed contract value without clear business justification
• Requests to split payments across multiple accounts, entities or payment methods without legitimate reason
• Payment from a third party not identified as the contracting client
• Requests to refund or redirect payments to accounts different from the originating account
• Client reluctance to provide KYC documentation or provide inconsistent information about their business
• Transactions inconsistent with the client's stated business purpose or industry
• Unusual urgency around payment processing without clear business justification

Handling of Suspicious Activity

EIDDI is a technology services provider, not a financial institution, and is not itself subject to Bank Secrecy Act suspicious-activity-reporting requirements. Nonetheless, where EIDDI has reason to suspect that a transaction may involve money laundering, terrorist financing or other financial crime, EIDDI will:

• Decline or suspend the transaction and, where appropriate, terminate the engagement
• Refer the matter to its regulated payment partners (such as Payoneer or Wise), whose own AML programmes include any required regulatory reporting
• Report the matter to the relevant authorities where EIDDI has a good-faith basis or legal duty to do so
• Cooperate fully with any lawful law enforcement or regulatory investigation

Record Keeping

EIDDI maintains records of all client identification documents, transaction records and AML-related correspondence for a minimum of five (5) years from the date of the transaction or the end of the business relationship, whichever is later, as a matter of internal policy and good commercial practice. Records are stored securely and are available for inspection by authorised regulatory authorities upon lawful request.

Sanctions Compliance

EIDDI screens all clients and transactions against the OFAC Consolidated Sanctions List, the EU Consolidated Sanctions List and other applicable sanctions databases prior to engagement and periodically during ongoing relationships. EIDDI will not provide services to any individual or entity subject to applicable sanctions, regardless of the nature of the services requested. Sanctions screening is conducted using commercially available compliance tools and updated as sanctions lists change.

Employee & Contractor Training

All EIDDI employees and contractors involved in client onboarding, contract management or payment processing receive training on this AML Policy, how to identify red flags and their responsibility to escalate suspicious activity internally for review. AML awareness training is conducted at onboarding and reviewed annually.

Policy Governance & Review

This AML Policy is reviewed annually and updated as required by changes in applicable law, regulatory guidance or EIDDI's business activities. The policy is approved by EIDDI's senior leadership and all employees are required to comply with it as a condition of engagement.

For AML-related questions or to report a concern: compliance@eiddisolutions.com

Client Obligations

By engaging EIDDI Solutions LLC, clients represent and warrant that:

• All funds used to pay EIDDI derive from legitimate, lawful sources
• The client is not subject to US or applicable international sanctions
• All information provided during KYC is accurate, complete and not misleading
• The client will promptly notify EIDDI of any material change in their business structure, beneficial ownership or regulatory status

Providing false or misleading information during KYC, or using EIDDI's services to facilitate financial crime, constitutes a material breach of the Terms of Service and will result in immediate termination of all engagements without refund, in addition to any legal remedies available to EIDDI.