AML / KYC / KYB Policy

Primera Business Group("Primera," "Company," "we"), an S corporation organized under the laws of the State of New York, with its principal address at 800 Third Avenue, Suite A, New York, NY 10022, USA, operates Ulasend and is committed to standards of anti-money laundering (AML) and counter-terrorist financing (CFT) compliance. Management and relevant employees are expected to follow these standards and to prevent activity that facilitates the legalization of illicit funds or the financing of terrorism.

These rules describe internal measures for customer due diligence, detecting suspicious or unusual behavior, and protecting the integrity of the Services. They apply alongside our Terms of Service and Privacy Policy.

• Money laundering — converting, transferring, acquiring, possessing, using, or concealing property derived from criminal activity, knowing of its illicit origin, or assisting others to evade consequences of such activity.
• Terrorist financing — allocating or raising funds to plan or perform terrorist acts or to finance terrorist organizations, knowing the funds will be used for those purposes.
• Customer / Merchant — a person or legal entity that partners with Primera to use Ulasend.
• UBO (ultimate beneficial owner) — a natural person who ultimately owns or controls more than 25% of a legal entity, or otherwise exercises ultimate effective control.
• PEP (politically exposed person) — a natural person who performs or has performed prominent public functions, plus certain family members and close associates, as commonly defined in AML standards.
• High-risk / risk country — jurisdictions with weak AML/CFT systems, high corruption, sanctions/embargoes, or terrorist financing risk, including lists published by FATF, the U.N., the U.S., the EU, or other credible sources.

We may require any Merchant—individual or corporate—to complete verification before or during use of the Services, and may re-verify at any time.

Individuals (KYC). We may collect and use: full name, date of birth, email, place of residence, payment/settlement wallet addresses, and similar data to provide Services, resolve claims, and communicate. Verification may be based on:

• Proof of identity (passport, national ID, or driver license showing name, photo, and date of birth);
• Proof of residence (utility bill, tax document, or bank reference generally not older than three months);
• Evidence of authority if acting for another person;
• Third-party KYC/AML tools, including biometric liveness checks, face-matching, and screening databases.

Legal entities (KYB). We may collect: legal name, date of incorporation, email, country of establishment, business address, settlement wallet addresses, and related data. Verification may include:

• Certificate of incorporation or commercial-register extract;
• Names and addresses of directors and beneficial owners;
• Identification of UBOs and understanding of ownership/control structure;
• Power of attorney or proof of authority for representatives;
• An AML letter describing the Merchant's own AML/KYC measures, if the Merchant provides financial services.

We verify data using credible independent sources and may use online databases. We may request additional information when identity or behavior raises risk. We may screen customers, representatives, directors, and UBOs against sanctions lists, including for example OFAC SDN, U.N. Security Council, EU/UK financial sanctions, and other comparable lists.

We may apply EDD when risk is higher, including when:

• There are doubts about submitted data, documents, or beneficial ownership;
• The customer is a PEP (other than a solely local PEP);
• The customer or a relevant counterparty is connected to a high-risk or sanctioned jurisdiction;
• Ownership is opaque, uses nominees/bearer shares, or is unusually complex for the business;
• Products favor anonymity, or payments arrive from unknown third parties;
• Onboarding or transaction patterns are unusual.

EDD may include additional documents from independent sources, more information on the purpose and nature of the relationship, and other risk-proportionate measures.

We are prohibited from transacting with sanctioned parties or in violation of applicable sanctions programs. Customers and related parties are screened periodically. Indicators of sanctions exposure receive heightened attention.

Customer, transaction, and relevant compliance records are kept so they can be produced on lawful request. Personal data, transaction data, and related information are generally stored for no less than five (5) years after termination of the business relationship, or longer if required by law or ongoing investigation.

Investigative effort is proportional to the risk and complexity of each case. We recognize risks from technologies that can fake location, commit fraud, or corrupt verification, and we aim to audit and harden controls accordingly.

We may contact you to clarify information or request materials needed for identification or risk assessment. Requests should be relevant to identified risks. We will not tip off customers that they are the subject of an internal suspicious-activity review in a way that prejudices that review.

Customer information may be reviewed on a periodic basis (for example annually) and whenever we believe information is outdated. Transaction monitoring may be triggered automatically or manually. Reviews may include customer profile, source of funds, activity versus expected behavior, counterparties, and documented findings supporting decisions.

Customers are checked against PEP databases or equivalent research. Accepting a non-local PEP generally requires senior approval, measures to establish source of wealth/funds, and enhanced ongoing monitoring.

We prefer low and normal risk relationships. Risk ratings may change over time. We may refuse or exit relationships where, for example, the customer is in a high-risk country on applicable lists, is sanctioned, is credibly linked to money laundering or terrorist financing, refuses to provide requested information, or is acting secretly for an undisclosed third-party beneficiary.

Illustrative risk categories:

• Low — established trustworthy behavior over a long relationship;
• Normal — no high-risk indicators; use matches expected profile;
• High — PEP links, adverse media, frozen assets related to terrorism financing, prior suspicious-activity history, identity doubts, avoidance of a formal relationship, or unexpected use of the Services.

Relevant personnel must promptly escalate suspicions of money laundering, terrorist financing, or unusual behavior to the person designated as Compliance Officer (or equivalent). Customers must not be notified that a report has been filed with authorities.

Where suspicion is well founded, Primera may file reports with competent authorities (including, where applicable, U.S. FinCEN or other agencies) and respond to lawful information requests. Reporting in good faith is not treated as a breach of confidentiality owed to the customer.

The Compliance Officer (or designee) oversees AML training, preliminary analysis of internal reports, record-keeping of escalations, and proposals to improve these rules.

Relevant employees receive AML/CFT training appropriate to their role, including onboarding training. Work product on customer reviews may be quality-checked for adequacy of research, documentation, and decisioning.

Ulasend onboarding collects account and business details, an Employer Identification Number (EIN), and the last four digits of an authorized representative's Social Security number. Every new merchant application is manually reviewed before dashboard and API access is enabled. Formal vendor-based KYC/KYB, automated sanctions screening, and enhanced monitoring may be introduced or expanded over time. Primera may request additional verification materials and may limit, freeze, or decline Services until requirements are met.

Using the Services means you agree to complete verification when asked, keep information current, and cooperate with monitoring requests.

Compliance questions: compliance@ulasend.com

Primera Business Group
800 Third Avenue, Suite A
New York, NY 10022, USA