Global AML/CTF & Sanctions Compliance Policy

Enablepay INC (Delaware, USA) and its operating subsidiary Enablepay Nigeria Limited (collectively "EnablePay") maintain a rigorous, institutional-grade compliance framework designed to prevent Money Laundering (ML), Terrorist Financing (TF), and Proliferation Financing (PF).

Operating as a regulated Money Services Business (FINTRAC MSB #N300001868) in North America, and as a licensed lending entity in Nigeria, EnablePay aligns its controls with the Financial Action Task Force (FATF) 40 Recommendations and the US Bank Secrecy Act (BSA). This framework enforces a zero-tolerance policy toward financial crime across all cross-border stablecoin settlements and domestic invoice discounting operations.

EnablePay utilizes a strictly business-to-business (B2B) operational model. We deal exclusively with verified corporate supply chains anchored by Tier-1 multinational corporations (e.g., Unilever, Coca-Cola). Because EnablePay does not process retail peer-to-peer (P2P) transfers, our baseline risk profile is inherently lower than standard consumer VASPs. However, our RBA dictates distinct risk categorizations:

• Low Risk: Domestic invoice discounting (Prime) for verified, legacy suppliers of Tier-1 Anchor Corporates within local fiat rails.
• Medium Risk: Cross-border stablecoin settlements (Nexus) to established manufacturing jurisdictions (e.g., China, India) requiring enhanced transaction monitoring.
• Prohibited (Zero Tolerance): Shell companies, unregistered MSBs, retail/individual consumers, darknet market interactions, and entities operating in comprehensively sanctioned jurisdictions (e.g., Iran, North Korea, Russia).

Before any facility is disbursed or stablecoin settlement is routed via the Delaware HoldCo, institutional-grade Corporate Due Diligence must be executed.

1. Corporate Identity: Algorithmic and manual verification of Certificates of Incorporation, Memorandums of Association, operating licenses, and tax identification numbers.
2. UBO Identification: Mandatory identification and identity verification (KYC) of all natural persons holding 25% or more equity or voting rights in the borrowing entity.
3. Commercial Validity (Proof of Life): Verification of the entity's commercial existence via direct API checks or manual validation against the Anchor Corporate's internal vendor databases.
4. Enhanced Due Diligence (EDD): Applied to entities operating in higher-risk sectors or those with Politically Exposed Persons (PEPs) in their executive structure. EDD requires senior compliance officer sign-off and enhanced Source of Wealth / Source of Funds (SoW/SoF) validation.

EnablePay utilizes automated, real-time API integrations with Tier-1 compliance data providers to screen all corporate clients, UBOs, and overseas settlement beneficiaries against global watchlists prior to onboarding and continuously thereafter.

Mandatory Watchlists Screened:

• US Treasury OFAC (SDN and Non-SDN lists)
• UN Security Council Consolidated List
• Canadian OSFI / FINTRAC Directives
• UK HMT / EU Consolidated Lists
• Nigeria NFIU / CBN Watchlists

Policy Directive: Any exact or highly probable probabilistic match results in an immediate, automated hard-stop of the transaction or onboarding process, pending manual resolution by the Chief Compliance Officer (CCO).

EnablePay utilizes USD-backed stablecoins (USDC) exclusively for cross-border liquidity routing. As a FINTRAC-regulated entity engaging in Virtual Asset transfers, we strictly adhere to FATF Travel Rule requirements.

1. Travel Rule Enforcement: EnablePay ensures that required originator and beneficiary data travels immediately and securely with all digital asset transfers exceeding the 1,000 USD/CAD equivalent threshold, utilizing compliant interoperability protocols when interfacing with external VASPs.
2. On-Chain Analytics & Wallet Screening: All external, unhosted wallets interacting with EnablePay’s corporate multi-sig smart contracts are continuously screened via industry-leading blockchain analytics software (e.g., Chainalysis KYT, TRM Labs).
3. Illicit Finance Blocking: Inbound or outbound funds associated with high-risk on-chain entities (e.g., mixers, tumblers, sanctioned addresses, or known ransomware clusters) are automatically rejected or quarantined at the smart contract level.

The Compliance Desk conducts ongoing monitoring of all fiat and stablecoin flows to detect unusual patterns deviating from the client’s established commercial profile.

Automated Red Flags Include:

• Invoice requests drastically inconsistent with the supplier's historical Anchor volume.
• Requests to route stablecoins to unrelated third-party overseas beneficiaries without valid proforma invoices.
• Sudden changes in corporate directorship or UBOs immediately preceding large capital drawdowns.

When reasonable suspicion of money laundering, terrorist financing, or sanctions evasion is identified, the CCO will file a Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR) with the appropriate Financial Intelligence Unit (e.g., FINTRAC in Canada, NFIU in Nigeria) within the statutory deadlines. Tipping off the client is strictly prohibited and constitutes a criminal offense under global law.

• Retention Policy: All KYB documents, transaction ledgers, fiat bank receipts, on-chain transaction hashes, and internal compliance memos are retained securely (encrypted at rest) for a minimum of seven (7) years following the termination of the business relationship or execution of the transaction.
• Independent Audit: The AML/CFT program is subject to an independent, third-party audit annually by a qualified firm to test the adequacy of the policies, procedures, and smart-contract internal controls.