Anti-Money Laundering Policy

Wellington Sovereign Corp, doing business as Nexzoneo ("Nexzoneo", "we", "us", or "our"), is committed to maintaining the highest standards of Anti-Money Laundering (AML) compliance. This policy establishes our framework for detecting, preventing, and reporting money laundering activities in accordance with applicable laws and regulations.

As a Money Services Business (MSB) registered with FinCEN, we are subject to the Bank Secrecy Act (BSA), USA PATRIOT Act, and related regulations. This policy applies to all Nexzoneo services, including payment processing, card issuance, and related financial services.

Our AML program complies with:

• Bank Secrecy Act (BSA) - 31 U.S.C. 5311 et seq.
• USA PATRIOT Act - Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act
• FinCEN Regulations - 31 CFR Chapter X
• OFAC Sanctions Programs - Office of Foreign Assets Control
• State Money Transmitter Laws - Including Montana and other jurisdictions where we operate

Our comprehensive AML program includes the following key components:

Customer Identification Program (CIP)

We verify the identity of all customers before establishing a business relationship. Our CIP includes:

• Collection of identifying information (name, date of birth, address, identification number)
• Verification of identity using reliable, independent sources
• Recordkeeping of identification documents and verification methods
• Enhanced due diligence for high-risk customers

Customer Due Diligence (CDD)

We conduct risk-based due diligence on all customers to understand:

• Nature and purpose of customer relationships
• Beneficial ownership of legal entity customers
• Expected transaction patterns and volumes
• Source of funds and wealth

Enhanced Due Diligence (EDD)

For high-risk customers, we perform enhanced due diligence including:

• Additional identity verification measures
• Enhanced monitoring of transactions
• Senior management approval for account opening
• Periodic review and update of customer information

Ongoing Monitoring

We continuously monitor customer transactions for suspicious activity using:

• Automated transaction monitoring systems
• Rule-based alerts and scenarios
• Pattern recognition and anomaly detection
• Manual review of high-risk transactions

Suspicious Activity Reporting (SAR)

We file Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Transactions involving $2,000 or more where we know, suspect, or have reason to suspect criminal activity
• Transactions designed to evade BSA requirements
• Transactions with no apparent lawful purpose
• Use of services to facilitate criminal activity

Currency Transaction Reporting (CTR)

We file Currency Transaction Reports (CTRs) for currency transactions exceeding $10,000 in a single day, including:

• Single transactions over $10,000
• Multiple transactions that aggregate to over $10,000 in a single day

We screen all customers and transactions against the Office of Foreign Assets Control (OFAC) sanctions lists, including:

• Specially Designated Nationals (SDN) List
• Consolidated Sanctions List
• Sectoral Sanctions Identifications List
• Foreign Sanctions Evaders List

Screening is performed at account opening, periodically throughout the customer relationship, and at the time of each transaction. Any matches are investigated immediately and reported to OFAC as required.

We maintain comprehensive records including:

• Customer Records: Identification information, CIP documentation, and verification records for 5 years after account closure
• Transaction Records: All transaction details for 5 years from date of transaction
• SARs and Supporting Documentation: For 5 years from filing date
• CTRs and Supporting Documentation: For 5 years from filing date
• AML Training Records: For 5 years

We employ a risk-based approach to AML compliance, assessing risk factors including:

Customer Risk Factors

• Customer type (individual, business, politically exposed person)
• Geographic location (high-risk jurisdictions)
• Products and services used
• Transaction patterns and volumes

Geographic Risk Factors

• Countries identified by FATF as high-risk or non-cooperative
• Countries subject to OFAC sanctions
• Regions known for drug trafficking, terrorism, or corruption

Product/Service Risk Factors

• Anonymous or pseudonymous payment methods
• High-value transactions
• Cross-border transactions
• Digital assets and cryptocurrency services

All employees receive comprehensive AML training appropriate to their roles and responsibilities:

• Initial Training: New employees complete AML training within 30 days of hire
• Annual Training: All employees complete refresher training at least annually
• Specialized Training: Compliance staff and senior management receive enhanced training
• Training Topics: BSA/AML laws, internal policies, red flags, reporting procedures

We have designated an AML Compliance Officer responsible for:

• Overseeing and implementing the AML program
• Ensuring compliance with BSA/AML regulations
• Coordinating SAR and CTR filings
• Managing employee training
• Conducting independent testing and audits
• Serving as the primary contact for regulatory authorities

The AML Compliance Officer reports directly to senior management and has authority to implement AML policies and procedures across the organization.

We conduct independent testing of our AML program at least every 12 months. Testing includes:

• Review of policies, procedures, and internal controls
• Assessment of CIP, CDD, and EDD processes
• Evaluation of transaction monitoring effectiveness
• Review of SAR and CTR filing procedures
• Testing of recordkeeping and retention
• Assessment of training program effectiveness

Testing is conducted by qualified independent third parties or internal audit staff not involved in AML compliance functions.

For questions regarding our AML policy or to report suspicious activity: