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Anti-Money Laundering (AML) Program

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1. Purpose

The purpose of this Anti-Money Laundering (AML) Program is to ensure that Radd Payment Solutions (“Radd”) maintains effective policies, procedures, and internal controls designed to detect and prevent the use of its payment infrastructure for:

  • Money laundering
  • Terrorist financing
  • Fraud
  • Sanctions violations
  • Other illicit financial activities

Radd recognizes that its services — which include payment processing, revenue stream assignment, billing management, and transaction aggregation — operate within regulated financial ecosystems. As such, Radd maintains an AML program consistent with expectations under the Bank Secrecy Act (BSA) and related regulations enforced by the Financial Crimes Enforcement Network (FinCEN).

The program is designed to:

  • Protect the integrity of the U.S. financial system
  • Protect Radd’s payment partners and financial institutions
  • Ensure compliance with federal AML standards
  • Mitigate financial crime risk across all payment channels managed by Radd

2. Scope

This AML Program applies to:

  • All employees of Radd Payment Solutions
  • All subsidiaries or special purpose entities controlled by Radd
  • All client merchants whose revenue streams are managed by Radd
  • All payment channels operated or facilitated by Radd

Including but not limited to:

  • Credit card processing
  • ACH and e-check payments
  • Online platform revenue
  • Recurring billing systems
  • Direct B2B invoicing
  • Subscription billing programs
  • Platform-based commerce integrations

3. AML Governance & Oversight

Radd maintains a governance structure designed to ensure effective AML oversight.

AML Compliance Officer

Radd designates an AML Compliance Officer responsible for administering and enforcing this AML Program.

Responsibilities include:

  • Oversight of AML policies and procedures
  • Monitoring transaction activity
  • Investigating suspicious activity
  • Coordinating with financial institutions
  • Ensuring compliance with regulatory obligations
  • Training employees on AML responsibilities
  • Maintaining AML documentation and audit readiness

The AML Compliance Officer reports directly to executive leadership.

4. Risk-Based AML Framework

Radd utilizes a risk-based approach to AML compliance.

This framework evaluates risk across the following categories:

Merchant Risk

Risk factors include:

  • Businesses in financial distress
  • Businesses undergoing restructuring
  • High transaction volumes
  • Rapid increases in payment activity
  • Businesses operating in historically high-risk sectors

Geographic Risk

Radd evaluates exposure to:

  • High-risk jurisdictions
  • Sanctioned countries
  • Regions associated with elevated financial crime risk

Payment Channel Risk

Certain payment channels carry increased risk, including:

  • Card-not-present transactions
  • Online platform transactions
  • Cross-platform payment aggregation
  • Third-party marketplace settlements

Transaction Risk

Transactions are monitored for indicators such as:

  • Unusual transaction volume spikes
  • Structured payments
  • Abnormal refund patterns
  • Rapid merchant onboarding followed by large processing volumes
  • Payment flows inconsistent with merchant business models

5. Customer Identification Program (CIP)

Prior to onboarding any client or merchant, Radd performs identity verification procedures consistent with industry best practices.

Required information includes:

  • Legal business name
  • Employer Identification Number (EIN)
  • Formation documents
  • Beneficial ownership information
  • Government-issued identification for controlling parties
  • Business address verification
  • Bank account verification

Radd may also obtain:

  • Articles of incorporation
  • Operating agreements
  • Business licenses
  • Ownership structure documentation
  • Verification of restructuring advisors or consultants

Failure to provide required documentation may result in denial or termination of services.

6. Know Your Customer (KYC)

Radd conducts due diligence to understand the nature of each client’s business operations.

KYC review includes:

  • Description of business activity
  • Expected payment volumes
  • Payment methods utilized
  • Industry classification
  • Customer base profile
  • Geographic markets served
  • Historical financial activity (when available)

Clients whose business models are inconsistent with disclosed operations may be rejected.

7. Beneficial Ownership Identification

Radd collects beneficial ownership information for all entities onboarded.

This includes identifying individuals who:

  • Own 25% or more of the legal entity
  • Exercise significant managerial control

Information collected includes:

  • Full legal name
  • Date of birth
  • Address
  • Identification number (SSN or passport)

8. Sanctions Screening

Radd screens all clients and beneficial owners against sanctions lists maintained by the Office of Foreign Assets Control (OFAC).

Screening occurs:

  • At onboarding
  • Periodically during the relationship
  • Upon changes to ownership structure

If a potential sanctions match is identified:

  • Accounts will be frozen
  • Transactions halted
  • Relevant authorities and banking partners notified

9. Transaction Monitoring

Radd monitors payment activity processed through its systems for suspicious behavior.

Monitoring includes:

  • Transaction velocity analysis
  • Volume threshold alerts
  • Refund and chargeback monitoring
  • Rapid account activity increases
  • Abnormal cross-platform revenue routing

Automated alerts and manual review processes are used to evaluate activity.

10. Suspicious Activity Reporting

If suspicious activity is detected, Radd will escalate internally for investigation.

Examples include:

  • Structured transactions designed to evade reporting thresholds
  • Payments inconsistent with stated business activity
  • Sudden large payment spikes without explanation
  • Payment activity involving sanctioned jurisdictions
  • Rapid movement of funds through multiple accounts

If required, Radd will cooperate with its banking partners to facilitate reporting obligations.

Financial institutions ultimately determine whether to file Suspicious Activity Reports (SARs) with FinCEN.

11. Recordkeeping

Radd maintains records related to AML compliance for a minimum of five (5) years.

Records maintained include:

  • Client onboarding documentation
  • Identity verification materials
  • Beneficial ownership information
  • Transaction records
  • Monitoring alerts
  • Internal investigation documentation
  • Compliance communications with banking partners

12. Employee Training

Radd provides AML training to all employees whose roles involve:

  • Client onboarding
  • Payment processing
  • Financial reconciliation
  • Client account management

Training includes:

  • Identifying suspicious transactions
  • Escalation procedures
  • AML reporting responsibilities
  • Sanctions awareness
  • Fraud indicators

Training occurs:

  • At onboarding
  • Annually thereafter

13. Independent Review

Radd’s AML program will be independently reviewed at least once every two years.

Reviews may be conducted by:

  • Independent compliance consultants
  • Legal advisors
  • Qualified third-party auditors

Reviews assess:

  • Effectiveness of AML policies
  • Compliance with regulatory expectations
  • Adequacy of transaction monitoring
  • Staff training effectiveness

14. Program Updates

This AML Program will be reviewed and updated periodically to address:

  • Changes in regulatory requirements
  • Expansion of Radd’s services
  • New payment channels
  • Emerging financial crime risks

15. Enforcement

Violation of this AML policy by employees or contractors may result in:

  • Disciplinary action
  • Termination
  • Reporting to relevant authorities if required

16. Policy Approval

This Anti-Money Laundering Program has been approved by the executive leadership of Radd Payment Solutions and is effective immediately.

Approved By

President
Radd Payment Solutions

Chief Operating Officer
Radd Payment Solutions

Date: __________________