Compliance Policy

1. Introduction

NetPay247 is committed to maintaining strong compliance, risk management, financial crime prevention, and customer protection standards across its platform and services.

This Compliance Policy explains how NetPay247 approaches compliance for its card services, IBAN services, business account solutions, payment infrastructure, Banking-as-a-Service solutions, merchant services, and related financial technology services.

NetPay247 may work with licensed banks, card issuers, BIN sponsors, electronic money institutions, payment processors, compliance vendors, technology providers, and regulated financial partners to provide certain services.

The purpose of this policy is to ensure that NetPay247 services are used only for lawful, approved, transparent, and compliant purposes.

2. Scope of This Policy

This policy applies to:

• Individual users
• Business users
• Corporate clients
• Merchants
• Platform partners
• BaaS partners
• Cardholders
• Authorized representatives
• Directors and shareholders
• Ultimate Beneficial Owners
• Employees, contractors, and service providers working with NetPay247
• Any person or entity using NetPay247 services directly or indirectly

This policy applies to all NetPay247 services, including but not limited to:

• Virtual card services
• Physical card services
• Business card programs
• IBAN services
• Virtual IBAN services
• Business account support
• Payment processing support
• Banking-as-a-Service solutions
• API-based financial infrastructure
• Merchant and platform services
• Transaction monitoring
• Compliance onboarding
• Account management services

3. Compliance Commitment

NetPay247 is committed to:

• Preventing money laundering
• Preventing terrorist financing
• Preventing fraud and financial crime
• Preventing sanctions violations
• Protecting users and business clients
• Supporting lawful financial activity
• Maintaining proper KYC and KYB controls
• Monitoring transactions for suspicious activity
• Cooperating with banking, issuing, payment, and compliance partners
• Meeting applicable legal, regulatory, and partner requirements
• Maintaining strong internal controls and risk review processes

NetPay247 does not support illegal, fraudulent, misleading, restricted, sanctioned, or high-risk activity.

4. Know Your Customer and Know Your Business

NetPay247 may conduct KYC and KYB checks before allowing users or businesses to access services.

For Individual Users

We may request:

• Full name
• Date of birth
• Nationality
• Country of residence
• Mobile number
• Email address
• Government-issued identity document
• Passport, national ID, Emirates ID, or equivalent document
• Selfie or liveness verification
• Proof of address where required
• Source of income
• Source of funds
• Purpose of account usage
• Any other information required for compliance review

For Business Users

We may request:

• Company name
• Company registration documents
• Trade license or certificate of incorporation
• Business activity details
• Business website
• Company ownership structure
• Director details
• Shareholder details
• Ultimate Beneficial Owner details
• Authorized representative details
• Proof of business address where required
• Expected transaction volume
• Countries of operation
• Source of funds
• Business model explanation
• Customer type and payment flow details
• Supporting invoices, contracts, or business proof where required

NetPay247 may reject, delay, suspend, or restrict access if the user or business fails to provide the required information.

5. Customer Due Diligence

NetPay247 applies customer due diligence measures to understand who our users are, what type of activity they conduct, and whether their activity matches the intended use of our services.

Customer due diligence may include:

• Identity verification
• Business verification
• Ownership verification
• Document verification
• Risk classification
• Sanctions screening
• Politically Exposed Person screening
• Adverse media screening
• Fraud checks
• Source of funds review
• Source of wealth review
• Review of transaction purpose
• Review of expected account activity

NetPay247 may conduct due diligence at onboarding and may repeat checks during the customer relationship.

6. Enhanced Due Diligence

NetPay247 may apply enhanced due diligence where a user, business, transaction, country, industry, ownership structure, or activity is considered higher risk.

Enhanced due diligence may include:

• Requesting additional documents
• Requesting source of funds evidence
• Requesting source of wealth evidence
• Reviewing invoices, contracts, or payment purpose
• Reviewing shareholder and UBO structure
• Reviewing business model and customer base
• Conducting additional screening
• Obtaining approval from compliance or risk teams
• Applying lower transaction limits
• Increasing monitoring frequency
• Restricting certain services

Enhanced due diligence may be required before approving card services, IBAN services, business accounts, payment flows, or BaaS-related services.

7. Sanctions Compliance

NetPay247 does not allow its services to be used by sanctioned individuals, sanctioned companies, prohibited entities, or users connected to restricted jurisdictions.

NetPay247 may screen users, businesses, directors, shareholders, UBOs, beneficiaries, senders, receivers, cardholders, merchants, and transactions against relevant sanctions lists and restricted party databases.

If a sanctions risk is identified, NetPay247 may:

• Reject onboarding
• Suspend account access
• Freeze or restrict services
• Block transactions
• Request additional information
• Report activity to partners or authorities where required
• Terminate the business relationship

Users must not use NetPay247 to avoid sanctions controls or hide the true nature of ownership, payment activity, or transaction purpose.

8. Anti-Money Laundering and Counter-Terrorist Financing

NetPay247 maintains AML and CTF controls designed to prevent its services from being used for money laundering, terrorist financing, illegal transfers, fraud, or other financial crime.

AML and CTF controls may include:

• KYC and KYB verification
• Customer risk scoring
• Transaction monitoring
• Screening of users and transactions
• Review of unusual payment activity
• Source of funds checks
• Review of high-risk countries or industries
• Review of rapid movement of funds
• Review of unusual card usage
• Review of suspicious IBAN activity
• Escalation of suspicious cases
• Record keeping
• Reporting to partners or authorities where required

NetPay247 may refuse, delay, block, return, freeze, or investigate transactions that appear suspicious or inconsistent with the user's profile.

9. Transaction Monitoring

NetPay247 may monitor transactions on an ongoing basis to detect suspicious, unusual, prohibited, or high-risk activity.

Transaction monitoring may apply to:

• Card transactions
• IBAN transactions
• Deposits
• Withdrawals
• Transfers
• Merchant payments
• Settlement activity
• Refunds
• Chargebacks
• Cross-border payments
• API-based payment flows
• Business account activity

Transaction reviews may consider:

• Transaction amount
• Transaction frequency
• Sender and receiver details
• Country of origin
• Destination country
• Merchant category
• Payment purpose
• Customer profile
• Business activity
• Transaction history
• Device and login behavior
• Risk indicators

NetPay247 may ask for supporting documents such as invoices, agreements, receipts, contracts, business proof, or explanation of payment purpose.

10. Prohibited and Restricted Activities

NetPay247 services must not be used for illegal, restricted, fraudulent, harmful, or unsupported activity.

Prohibited or restricted activities may include:

• Money laundering
• Terrorist financing
• Fraud
• Scams
• Fake documents
• Identity theft
• Sanctions evasion
• Illegal gambling
• Unlicensed financial services
• Unlicensed money transmission
• Illegal crypto activity
• Ponzi schemes
• Pyramid schemes
• High-risk investment schemes
• Counterfeit goods
• Stolen goods
• Narcotics or controlled substances
• Weapons or illegal arms trade
• Human trafficking
• Adult exploitation
• Illegal online content
• Tax evasion
• Shell companies with no clear purpose
• Businesses hiding true ownership
• Transactions with no lawful purpose
• Any activity prohibited by law, banks, card networks, payment processors, or NetPay247 partners

NetPay247 may update its restricted activity list from time to time based on legal, regulatory, partner, and internal risk requirements.

11. High-Risk Industries

Some industries may require additional review or may not be supported depending on banking partner, issuer, processor, jurisdiction, or compliance requirements.

High-risk industries may include:

• Crypto-related businesses
• Gaming and gambling-related businesses
• Financial services businesses
• Money service businesses
• Investment platforms
• Forex, CFD, or trading-related businesses
• Adult content businesses
• Travel businesses with high chargeback risk
• Telemarketing businesses
• Subscription businesses with high refund risk
• Marketplace businesses
• Cross-border payment businesses
• High-risk e-commerce businesses
• Any business with unclear source of funds or ownership structure

Approval is not guaranteed for high-risk industries. NetPay247 may request enhanced due diligence before providing services.

12. Card Program Compliance

Users and businesses using NetPay247 card services must comply with applicable card network rules, issuer requirements, BIN sponsor requirements, transaction rules, chargeback rules, and fraud prevention standards.

NetPay247 may monitor card activity for:

• Unauthorized transactions
• Suspicious merchant activity
• High decline rates
• Unusual spending patterns
• Excessive chargebacks
• Card testing
• Fraud attempts
• Use in prohibited merchant categories
• Use in restricted countries
• Misuse of virtual or physical cards

NetPay247 may block, freeze, replace, restrict, or cancel cards where required for compliance, fraud prevention, security, partner rules, or legal reasons.

13. IBAN and Account Compliance

Users and businesses using NetPay247 IBAN or account services must ensure that all incoming and outgoing payments are lawful, accurate, properly authorized, and supported by a valid business or personal purpose.

NetPay247 may review IBAN transactions for:

• Suspicious incoming payments
• Suspicious outgoing transfers
• Unclear payment purpose
• High-risk sender or receiver
• Unsupported countries
• Sanctions risk
• Unusual payment pattern
• Rapid fund movement
• Mismatch with business activity
• Third-party payment risk
• Use of accounts for unauthorized money transmission

NetPay247 may reject, freeze, return, delay, or request further information for any IBAN transaction.

14. BaaS and Partner Compliance

Businesses using NetPay247's Banking-as-a-Service or infrastructure solutions must maintain strong compliance standards for their own customers, users, merchants, or cardholders.

Business and BaaS partners may be required to:

• Conduct customer due diligence
• Maintain customer records
• Verify customer identity
• Screen customers and transactions
• Monitor suspicious activity
• Follow approved onboarding processes
• Disclose accurate service terms to their users
• Maintain proper privacy policies and user agreements
• Cooperate with NetPay247 compliance reviews
• Report suspicious activity where required
• Avoid onboarding prohibited users or industries

NetPay247 may audit, review, suspend, or terminate BaaS partnerships if compliance standards are not met.

15. Fraud Prevention

NetPay247 may use fraud prevention tools, internal controls, device checks, transaction rules, and risk indicators to protect users and partners.

Fraud prevention controls may include:

• Device fingerprinting
• IP monitoring
• Login monitoring
• Velocity checks
• Card testing detection
• Transaction pattern analysis
• Blacklist and watchlist checks
• Suspicious merchant review
• Chargeback monitoring
• Manual transaction review
• Account takeover detection
• Document fraud detection

If fraud is suspected, NetPay247 may immediately restrict access, block transactions, freeze accounts, cancel cards, or request additional verification.

16. Reporting Suspicious Activity

NetPay247 may report suspicious activity to banking partners, issuing partners, payment processors, regulators, law enforcement, or government authorities where required.

Suspicious activity may include:

• Use of fake documents
• Attempted sanctions evasion
• Money laundering indicators
• Terrorist financing indicators
• Fraud attempts
• Unauthorized account use
• Suspicious third-party payments
• Unusual card activity
• Unusual IBAN activity
• Repeated failed verification attempts
• Unexplained fund movement
• Refusal to provide requested documents

NetPay247 may not be able to inform users about certain reports or investigations due to legal, regulatory, or partner restrictions.

17. Record Keeping

NetPay247 may keep records related to onboarding, KYC, KYB, transactions, compliance reviews, risk assessments, communication, account activity, and investigations.

Records may include:

• Identity documents
• Business documents
• Verification results
• Screening results
• Transaction records
• Compliance notes
• Risk reviews
• Supporting documents
• Communication records
• Dispute and chargeback records
• Account closure records

Records may be retained for the period required by applicable law, regulation, partner requirements, dispute resolution, audit, fraud prevention, or internal compliance policies.

18. User Responsibilities

Users and businesses must:

• Provide true and accurate information
• Keep account information updated
• Use NetPay247 services only for lawful purposes
• Cooperate with compliance checks
• Provide documents when requested
• Avoid prohibited or restricted activities
• Ensure transactions have a lawful purpose
• Keep login credentials secure
• Report suspicious or unauthorized activity
• Follow NetPay247 terms, policies, and partner requirements

Failure to meet these responsibilities may result in account restriction, transaction rejection, service suspension, or account closure.

19. Account Review, Suspension and Closure

NetPay247 may review, suspend, restrict, freeze, or close accounts if:

• Compliance information is incomplete
• Documents are false or expired
• Suspicious activity is detected
• Fraud is suspected
• Sanctions risk is identified
• Prohibited activity is found
• User refuses to provide requested information
• Partner approval is withdrawn
• Transaction activity does not match user profile
• Account is used for unauthorized purposes
• Legal or regulatory requirements demand action

NetPay247 may act without prior notice where required for compliance, security, legal, regulatory, or partner-related reasons.

20. Cooperation With Partners and Authorities

NetPay247 may cooperate with banks, issuers, BIN sponsors, payment processors, card networks, compliance providers, regulators, courts, law enforcement agencies, and government authorities.

This cooperation may include:

• Providing compliance records
• Sharing transaction information
• Responding to legal requests
• Blocking or freezing transactions
• Investigating suspicious activity
• Supporting fraud investigations
• Complying with regulatory obligations
• Following partner instructions

NetPay247 may take any action required by its partners or authorities to comply with applicable obligations.

21. Training and Internal Controls

NetPay247 may maintain internal compliance controls to support safe and responsible operations.

These may include:

• Compliance policies
• Risk review processes
• Internal approval workflows
• Staff training
• Access controls
• Transaction monitoring rules
• Document review procedures
• Escalation procedures
• Partner reporting procedures
• Periodic compliance reviews

NetPay247 aims to continuously improve its compliance controls as the platform, services, risks, and regulatory environment evolve.

22. Policy Updates

NetPay247 may update this Compliance Policy from time to time based on changes in services, laws, regulations, partner requirements, risk standards, or internal procedures.

When this policy is updated, the effective date may be changed. Continued use of NetPay247 services after updates means you accept the revised policy.

23. Contact Us

For compliance-related questions, document requests, risk reviews, or account concerns, you can contact us at:

NetPay247

Website: www.netpay247.com

Email: support@netpay247.com

Please mention “Compliance Request” in the subject line so the request can be reviewed by the appropriate team.

24. Important Notice

NetPay247 provides financial technology, card, IBAN, account, payment, and Banking-as-a-Service related solutions through its platform and partners.

Access to NetPay247 services is subject to compliance approval, partner approval, jurisdictional availability, risk assessment, and applicable legal or regulatory requirements.

NetPay247 reserves the right to refuse, restrict, suspend, freeze, or terminate services where required for compliance, fraud prevention, legal, regulatory, partner, operational, or risk management reasons.