Compliance

PAYNOMIC FINANCE CORP. is preparing to operate a compliance-first OTC digital asset brokerage model.

The Company intends to maintain internal controls designed to support:

• AML/KYC compliance;
• sanctions screening;
• risk-based due diligence;
• transaction monitoring;
• onboarding governance;
• escalation and review procedures.

AML/KYC Framework

The Company applies a risk-based onboarding and monitoring framework designed to identify and mitigate financial crime risks.

Client Due Diligence

Clients may be required to provide:

• identification information;
• corporate documentation;
• beneficial ownership information;
• source of funds information;
• additional documentation depending on risk profile.

Sanctions Screening

The Company intends to apply sanctions screening procedures and reserves the right to refuse onboarding or decline transactions where sanctions concerns arise.

Enhanced Due Diligence

Higher-risk relationships may be subject to enhanced due diligence procedures and additional review requirements.

Monitoring & Review

The Company intends to apply transaction monitoring and ongoing review procedures appropriate to its operational model and risk profile.

Right to Refuse Service

The Company reserves the right to refuse onboarding, restrict activity, delay processing, or terminate relationships where:

• risk cannot be appropriately mitigated;
• required information cannot be obtained;
• sanctions concerns arise;
• activity appears inconsistent with the stated client profile;
• applicable legal or internal compliance requirements require restriction.