AML and Sanctions Statement

Commitment

YembiPay will not be used to launder money, finance terrorism, evade sanctions, or move the proceeds of crime. Compliance controls sit in the execution path of every settlement rather than beside it: a settlement that fails screening does not execute, and there is no fast path around screening for any customer, corridor, or amount.

Framework

The program is built on the Financial Action Task Force recommendations as applied in the Caribbean by the Caribbean Financial Action Task Force, and on the laws of the corridors YembiPay serves and the jurisdictions in which it operates. That includes the anti-money-laundering and proceeds-of-crime legislation and central bank guidance of Jamaica and Guyana, the proceeds-of-crime and digital asset business regimes of Bermuda, and the United States sanctions regime, which binds the US dollar and stablecoin legs of every settlement. Where regimes differ, the program applies the stricter standard.

Customer identification

Every organization is identified and verified before it can move value. YembiPay collects the legal entity name and registration number, the registered address and country, the ownership structure and the identity of each beneficial owner holding 25 percent or more, the identity of directors and authorized signatories, and a source-of-funds declaration. Identity documents are verified through an independent identity verification provider. Organizations that settle on behalf of their own customers must maintain their own customer due diligence and produce it on request. Verification is repeated when ownership or control changes and periodically according to risk.

Risk rating and enhanced due diligence

Each organization and each corridor receives a risk rating based on geography, activity, ownership, expected volume, and behaviour. Enhanced due diligence, including source-of-wealth documentation, statement of purpose, senior management approval, and closer monitoring, applies to higher-risk ratings, to politically exposed persons and their associates, to the restricted activities listed in the Acceptable Use policy, and to corridors with elevated regional or international risk assessments. Ratings are reviewed on a schedule and on any trigger event.

Screening on every settlement

• Sanctions. The names of the organization, its operators and beneficial owners, and every originator and beneficiary are screened against sanctions lists that are refreshed daily. Wallet addresses are screened against addresses published on those lists.
• Issuer address lists. Before the on-chain leg, the destination and source addresses are checked against the stablecoin issuer's own block list. A clear result means only that the issuer's contract did not report the address as blocked at that moment. It is not a determination of legal status, registration, licensing, or compliance with any statute.
• Monitoring. Velocity, amount, corridor, and behavioural rules run on every settlement and produce reviewable events without logging sensitive raw data.
• Travel Rule. At or above USD 3,000, originator and beneficiary identifying information is required before execution and is transmitted to the counterparty institution where one exists.
• Risk score. The results combine into a per-settlement risk score that is recorded on the compliance certificate.

Screening is automated. Blocks and holds are reviewed by a person before any relationship is ended, and an organization can ask for human review of an automated outcome through legal@yembipay.com, subject to the no-tipping-off rule below.

Reporting

Large settlements at or above USD 10,000 are recorded for threshold reporting where a corridor requires it. Suspicious activity identified by a rule, by a reviewer, or by a partner is escalated to the designated compliance officer, who decides whether a report to the relevant financial intelligence unit is required and files it. YembiPay does not tell an organization or a customer that a report has been made or is being considered, and will not explain a screening match where doing so would breach that rule.

Blocked and held settlements

A settlement that matches a sanctions list, is addressed to or from a blocked address, exceeds a limit, or triggers a monitoring rule is held before execution and reported to the organization as held through the API and by webhook. It is reviewed, then executed, returned, or retained under a legal order, as described in the Settlement, Quote, and On-Chain Terms. Value that is the subject of a sanctions block or a legal order is not returned until the block or order permits it.

Governance

A designated compliance officer is accountable for the program, receives internal escalations, files external reports, and reports to senior management. The appointment is published with the contracting entity's details. The program is reviewed annually by the compliance officer and periodically by an independent reviewer, and after any material regulatory change or enforcement action. Everyone with access to the platform completes training on joining and annually.

Cooperation

YembiPay cooperates with regulators, financial intelligence units, law enforcement, stablecoin issuers, and partner institutions, within the limits of data protection law and the procedures in Legal and Law-Enforcement Requests.

Scope

This statement summarizes a program; it is not the program, it is not legal advice, and it is not a representation that YembiPay is licensed or registered. A compliance certificate records that these controls ran on one settlement and what they found. It is not a determination of any party's legal status.