Sanctions Compliance Policy

TruePay Ltd. (TruePay”) and all its subsidiaries and affiliated companies must comply with the sanctions laws and regulations of the United Nations, the European Union, the United Kingdom, the United States, and all other applicable sanctions laws and regulations in all jurisdictions in which TruePay operates.

To this end, Our Global Sanctions Policy, identified the following as the minimum standards, with which TruePay and all its subsidiaries and affiliated entities must comply:

• To screen all customers and applicable transactions globally against sanctions lists issued by among others, the United Nations, the United Kingdom, the European Union, and he United States.

• To screen against other local sanctions lists that apply to TruePay’s operations in a particular jurisdiction.

• To prohibiting business activity, including commencing or continuing customer relationships or providing products or services or facilitating transactions that TruePay deems to be in violation of applicable sanctions laws or its internal Global Sanctions Policy. This includes prohibitions on business activity with individuals or entities named on a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions programmes. Currently, these countries and territories are Cuba, Iran, North Korea and Syria, as well as Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia regions.

• To restrict Transactions related to certain business activity involving, directly or indirectly, countries or persons subject to selective or targeted sanctions programmes. These selective country programmes prohibit transactions and services relating to specific types of products or services and target certain industry sectors or governments, including:

-- the provision of funding to/from the governments of Belarus, Libya, Sudan or Zimbabwe; -- certain activity involving the Government of Venezuela (the term “Government of Venezuela” includes The state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (“PdVSA”), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime); -- certain transactions and services involving the Russian financial, energy and defence sectors;

• To investigate all customer/client alerts or transactions that are stopped in TruePay’s screening systems. While TruePay seeks to investigate these alerts and transactions in a reasonable timeframe, compliance with applicable sanctions laws or its internal Global Sanctions Policy may result in delays to the processing of customer transactions while additional due diligence is conducted and information obtained on the nature of the underlying transaction or the parties involved.

• To block or reject transactions where TruePay is required to do so under applicable sanctions laws and regulations or its own internal Global Sanctions Policy. Transactions may also be returned by TruePay where there are no freezing or reporting obligations but transactions are deemed to be outside of TruePay’s risk appetite.

• Reporting breaches of sanctions laws to the relevant regulatory authorities. This can include any attempt by a customer to evade sanctions laws.