Anti-Money Laundering Statement

Concrete Gate Limited

Last Updated: 13.03.2026

1. INTRODUCTION AND PURPOSE OF THE POLICY

1.1. Concrete Gate Limited (hereinafter - the "Company") strictly adheres to international standards for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF), including FATF recommendations and EU Directives.
1.2. The purpose of this policy is to minimize the risks of the Company's technical infrastructure being utilized for illicit financial operations.

2. "KNOW YOUR CUSTOMER" PRINCIPLE (KYC / KYB)

The Company applies a Risk-Based Approach (RBA) when verifying merchants. The verification process consists of three levels:

2.1. Business Identification (KYB)

Prior to the activation of the payment gateway, the Merchant is required to provide:

• Certificate of Incorporation.
• Articles of Association (or Bylaws).
• Documents confirming ownership and management structure.
• Register of Directors and Shareholders.

2.2. Identification of Beneficial Owners (UBO)

We identify all natural persons who own or control more than 25% of the company's shares. The following are mandatory for these individuals:

• A copy of a valid international passport or ID card.
• Proof of Address (e.g., a utility bill or bank statement issued within the last 3 months).

2.3. Sanctions Screening

All clients are screened against global databases, including:

• UN, EU, and OFAC Sanctions Lists.
• Politically Exposed Persons (PEP) lists.

3. TRANSACTION MONITORING AND "RED FLAGS"

Although the Company acts as a technical provider, we implement automated monitoring systems to detect suspicious activity, including but not limited to:

• Structuring: Breaking down large transactions into a series of smaller payments to evade thresholds.
• Anomalous Spikes: A sudden, unexplained surge in transaction volume.
• Geographic Inconsistencies: The use of cards from high-risk regions that do not match the payer's IP address location.
• High Chargeback Ratio: Which may indicate the unauthorized use of card data or fraudulent business practices.

4. RISK RATING

Each merchant is assigned a risk level:

• Low Risk: Transparent businesses operating in highly regulated jurisdictions.
• Medium Risk: Newly established companies or businesses in sectors with high turnover.
• High Risk: Requires Enhanced Due Diligence (EDD). This category includes merchants from countries on the FATF "Grey List" or high-risk industry sectors.

5. DENIAL OF SERVICE

The Company shall not enter into a business relationship, and shall immediately terminate existing ones, if:

• The submission of forged or fraudulent documents is detected.
• The merchant’s business is associated with Prohibited Activities (e.g., unlicensed weapon sales, illegal gambling, etc.).
• The merchant or its beneficial owners appear on international sanctions lists.

6. DATA RETENTION

In accordance with EU regulatory standards, all verification data (KYC/KYB) and transaction logs are stored securely for a period of 5 years following the termination of the agreement with the Merchant.