Anti-Money Laundering Statement

CentaPay Limited is authorised by the Astana Financial Services Authority (AFSA) as a Money Services Provider within the Astana International Financial Centre (AIFC).

We are committed to preventing the use of our payment infrastructure for money laundering, terrorist financing, sanctions evasion, or any other form of financial crime. We maintain a compliance programme that is proportionate to our business model, the jurisdictions in which we operate, and the nature of the payment flows we process.

Our AML/CTF programme is designed to comply with:

• the AFSA Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules;
• the AIFC General Rules (GEN);
• applicable provisions of Kazakhstan's AML/CTF legislation; and
• relevant guidance from the Financial Action Task Force (FATF).

CentaPay applies a risk-based approach to financial crime prevention. Key elements include:

• Customer due diligence — we identify and verify all clients and their beneficial owners before establishing a business relationship, and apply enhanced measures where we assess a higher level of risk.
• Ongoing monitoring — we monitor client relationships and transaction activity on an ongoing basis to identify unusual or potentially suspicious patterns.
• Sanctions compliance — we screen clients and relevant parties against applicable sanctions lists at onboarding and on an ongoing basis.
• Governance — our compliance programme is overseen by dedicated compliance and reporting functions with direct access to the Board of Directors.
• Training — all relevant staff receive AML/CTF training at induction and on a recurring basis.

CentaPay cooperates fully with AFSA, law enforcement, and other competent authorities in connection with their investigations and inquiries. We respond promptly to lawful requests for information and provide any assistance required under applicable law.