UAB Nuvei Risk Policy

1. PURPOSE AND SCOPE

1.1. UAB Nuvei, herein referred to as “Nuvei” or the “Entity” is a licensed electronic money institution.

1.2. The Entity specializes in providing payment services, multicurrency and operational accounts primarily to other obliged entities such as other electronic money or payment institutions, non-bank financial institutions ("NBFIs"), virtual asset service providers, gambling operators and small-mid-to-large scale corporate entities. The intent of this Anti-Money Laundering / Counter Terrorist Financing ("AML/CTF") Risk Appetite Policy (hereafter referred to as "the Policy") is to delineate Nuvei risk tolerance parameters and establish guidance for the identification, quantification, reporting, management, and surveillance of Money Laundering and Terrorist Financing ("ML/TF") risks, in adherence to applicable legal requirements.

1.3. Given its business model, Nuvei also incurs reputational risk associated with the possibility of its clientele processing funds linked to Money Laundering or Terrorism Financing activities, circumventing sanctions or other financial crimes, potentially involving the Entity in such transactions.

2. PRODUCTS AND SERVICES

2.1. Nuvei products and services strictly shall be used in accordance to their purpose and as instructed by the commercial teams, exemplary instances:

2.1.1. Settlement accounts to conduct settlements;

2.1.2. Operational accounts to pay salaries and make vendor payments;

2.1.3. Accounts for end users to on ramp and off ramp their accounts on the customer’s infrastructure;

2.1.4. Other use case.

2.2. In case of unclarities and questions regarding the usage of products and services, the customers or applicants shall reach out to relationship manager.

3. ACCEPTED BUSINESSES

3.1. Nuvei will refrain from onboarding Clients engaged in unlawful businesses or activities lacking necessary licenses or permissions, or those posing significant reputational risks, including adverse media coverage. This principle extends to Correspondent Banking relationships, where Nuvei's Clients' customers must also adhere to these standards.

This implies, inter alia, that:

• As required, Clients (and in the case of Correspondent Banking relationships, Nuvei’ Clients’ underlying customers) must hold the appropriate licenses or permissions to operate and provide services/sell goods in their countries/territories of establishment, and in the countries/territories they provide services or sell goods to;
• As required, products and services sold or provided by Nuvei Clients (and in the case of Correspondent Banking relationships, Nuvei Clients’ underlying customers) must comply with applicable legal or regulatory standards.

3.2. Scenarios:

There are various scenarios concerning Clients and Payment flows, including:

3.2.1. A direct Client of Nuvei:

a. Payment flows encompass:

i. A remitter (not a Client of Nuvei), sending funds to a Client of Nuvei

ii. A beneficiary, (not a Client of Nuvei), receiving funds from a Client of Nuvei

iii. A conversion to/from virtual assets (in the form of stablecoins pegged to a single currency) where this is facilitating payment infrastructures.

3.2.2. A customer of a PSP Client of Nuvei

a. Payment flows encompass:

i. A remitter (not a customer of Nuvei PSP Client), sending funds to a customer of Nuvei PSP Client

ii. A beneficiary, (not a Client of Nuvei), receiving funds from a customer of Nuvei PSP Client

4. PROHIBITED CLIENT CATEGORIES AND PROHIBITED PAYMENT FLOWS

1. Nuvei does not permit pay in or pay outs from its accounts in physical cash. Nuvei does not onboard, nor will it process the payment flows for its PSP Clients, for the following:

2. Groups, legal bodies or similar subject to international sanctions or embargoes, in particular as issued by the Financial Crime Investigation Service (“FCIS”), the European Union (“EU”), the United Nations (“UN”), HM Treasury (UK), or the US Office of Foreign Assets Control (“OFAC”);

3. “Non-standard” or “non transparent” activities – those carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency or which do not meet international banking standards;

4. Bidding fee auctions, penny auctions, or any type of all-pay auction in which all participants must pay a non-refundable fee to place each small incremental bid;

5. Shell banks; (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups);

6. Shell companies; (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);

7. Bearer share corporations and companies connected to nominee or similar arrangements for the purpose of hiding or mask the true beneficial ownership (some trust structures may be permitted, depending on the merits of the case and there is no suggestion of untoward behaviour);

8. Physically present Adult Services – this includes, but is not limited to, Escort services, Solicitation thereof, sale and/or advertising or suggestion of any physical sexual services that may imply or suggest prostitution, regardless whether it is legal in the specific country involved;

9. Unregulated, unlicensed or offshore holding/investment companies involved in managing or investing own- or third-party funds (This does not include regulated investment companies or regulated investment funds in Countries permitted for Correspondent Banking relationships);

10. Any involvement in the sale or marketing of Binary Options;

11. Weapons of war, automatic weapons, ammunitions or defence equipment: Includes merchants involved in the sales, intermediation or commerce of war or automatic weapons, including but not limited to chemical weapons, cluster bombs, ammunitions, or other defence equipment or similar.

12. Marijuana industry and other drug industries, including tools and instruments to make and use drugs;

13. Dealers in precious metals, stones and rough diamonds;

14. Debt restructuring, debt settlement, providing credit, debit  collections;

15. Crowdfunding projects raising funds for a specific cause or project to be donated by natural persons;

16. Chemicals, hazardous chemicals and allied products;

17. Fake good and counterfeit consumer products, high fashion goods;

18. Fine art dealers and dealers in cultural objects like sculptures, antiques and collector’s items;

19. Merchandise in wildlife or wildlife products regulated under CITES;

20. Production or trade in radioactive materials;

21. Production or trade in pesticides/herbicides subject to international phase outs or bans;

22. Trading of Fireworks, explosives, and nuclear weapons;

23. Trade in human body parts, liquids, pallets;

24. Marriage, bridal order by mail;

5. RESTRICTIONS ON DIRECT CLIENTS

1. Nuvei will not directly onboard any of the following Client types. Nuvei PSP Clients may have the following as their underlying customers, subject to additional due diligence and approvals:

2. Adult services that are not physically present, this includes dating sites, websites with adult content or products, and pornography businesses. If any payments are to be made to, or received from, a business providing these services the following restrictions also apply. These businesses must:

3. Have no suggestions of escort services, or the sale of physically present sexual services (solicitation/prostitution);

4. Have no material negative media which could result in material reputational damage for Nuvei and’

5. Be incorporated within Europe, UK or North America.

6. Any business involved with Cannabidiol “CBD”. These businesses must:

7. Be able prove that the Tetrahydrocannabinol “THC” content is within legal limits, and prove that this is continually monitored and tested;

8. Possess the appropriate licenses in those jurisdictions where they are established, or sell products into; and

9. Have been onboarded by the PSP Client with appropriate onboarding procedures and controls to address the risks associated with this Business type. These procedures and controls may be assessed by Nuvei before approval to proceed is provided.

10. Charities, social service organisations and other non-profit or political organisations. These businesses must:

11. Be registered, or local equivalent, in the country of incorporation;

12. Not be located in extra high-risk countries (as defined by Nuvei), and must not use Nuvei to pay to any restricted countries;

13. Not sponsor or support any act of violence or hate

6. RESTRICTED CLIENT CATEGORIES AND RESTRICTED PAYMENT FLOWS

1. Nuvei has placed restrictions on the Client types listed below.

2. The Client types and restrictions are:

3. Affiliate Marketing schemes, including network marketing, referral marketing, multilevel marketing. These businesses must:

4. Not be established as a multilevel scheme for the purpose of circumventing credit card schemes rules;

5. Comply, in letter and in practice, with distant marketing or online selling legislation, including US negative option features and EU withdrawal rights, or equivalent;

6. Not engage in aggressive tax planning or transfer pricing, make use of nominees or similar structures to hide or mask true beneficial ownership of the entities involved in the scheme;

7. Not have unfair pricing or charges, or withdrawal / cancellation rights that cannot be effectively exercised without unfair costs or penalties.

8. Corporate service provider and other legal and accounting services. To be a direct Client Nuvei or a customer of a PSP Client of Nuvei these businesses must:

9. Have licensing/registration in the countries permitted for Correspondent Banking relationships

NOTE: If any payments are to be made to, or received from, a Corporate service provider and other legal and accounting services on behalf of a direct Client of Nuvei, or on behalf of a customer of a PSP Client of Nuvei, the above restriction does not apply to the payment.

10. Virtual Currencies / Cryptoasset firms (i.e. firms engaged in exchange services between virtual currencies and fiat currencies). These businesses must:

12.1. Be registered / authorized and under supervision by a competent authority in the UK/EEA or in countries approved for Correspondent Banking relationships and comply with FATF recommendation relevant for virtual currencies;

12.2. The experience of the senior management and leadership team must be of an acceptable risk profile, including the experience and qualifications of the MLRO; Compliance team and Onboarding team. (The MLRO, Compliance team and Onboarding team must not have any conflicts of interest, for example they should be independent of any income generating departments);

12.3. Not offer any privacy coins or any encrypted transactions adding anonymity.

12.4. Have in place appropriate transaction monitoring tools, which includes identifying signs of mixers/tumblers. These tools must be deemed satisfactory upon review be accepted by Nuvei AML department. An expectation is that the monitoring must have solid Know Your Transaction methodologies.

11. Gambling. These businesses must:

13.1. Be incorporated in one of the following jurisdictions: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Lithuania, Finland, France, Germany, Gibraltar, Greece, Greenland, Hungary, Isle of Man, Italy, Latvia, Malta, Poland, Portugal, Romania (subject to the business holding 2nd Class Gambling license), Spain, Slovakia, Sweden and United Kingdom. Additional countries may only be accepted with explicit approval from Nuvei’s MLRO;

13.2. Only perform the following activities: online gambling, betting, poker, sport, horse racing, skill games, casino, lottery, arcade;

13.3. Have a relevant license (as required) where they are established or provide services to, including by means of a website in a country-specific language;

13.4. Be registered on the local countries gambling commission;

13.5. Be subject to European MLDs or UK equivalent;

13.6. Have no material negative media which could result in material reputational damage for Nuvei;

7. PROHIBITED COUNTRIES FOR SWIFT PROCESSING IN ANY OF THE CURRENCIES

7.1. FATF’s Blacklist (non-cooperative countries), FATF’s Greylist (closely monitored jurisdictions), EU high-risk countries: Afghanistan, Barbados, Bulgaria, Burkina Faso, Cameroon, Croatia, Democratic Republic of the Congo, North Korea, Gibraltar, Haiti, Iran, Jamaica, Kenya, Mali, Monaco, Mozambique, Myanmar, Namibia, Nigeria, Panama, Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Trinidad and Tobago, Uganda, United Arab Emirates, Vanuatu, Venezuela, Vietnam, Yemen.