Hoodpay, LLC ("Hoodpay") is committed to preventing the use of its services for money laundering or any activities that facilitate money laundering, terrorist financing, or other illicit financial activities. Hoodpay has implemented a comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance program to ensure compliance with the Bank Secrecy Act, the USA PATRIOT Act, the economic and trade sanctions programs administered by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury, and other applicable laws and regulations. Hoodpay is also a registered Money Service Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000240038998.

This policy applies to all Hoodpay employees, agents, and partners involved in the provision of Hoodpay's services. It is designed to ensure that all parties understand their obligations and responsibilities in preventing money laundering and terrorist financing.

Role and Responsibilities

Hoodpay has designated a qualified Compliance Officer responsible for overseeing and ensuring the implementation and effectiveness of the AML and CTF compliance program. The Compliance Officer's responsibilities include:

a. Developing and maintaining AML and CTF policies and procedures.

b. Providing guidance to employees on AML and CTF-related matters.

c. Ensuring timely reporting of suspicious activities to the appropriate authorities.

d. Coordinating with regulatory authorities and law enforcement as necessary.

e. Staying up-to-date with relevant laws and regulations and implementing necessary updates to the compliance program.

Identification and Verification

Hoodpay's KYC and CDD process includes collecting and verifying customer identification information, such as:

a. For individuals: name, address, date of birth, and government-issued identification number.

b. For legal entities: legal name, principal place of business, and other relevant information.

c. For beneficial owners of legal entities: name, address, date of birth, and government-issued identification number.

Risk Assessment

Hoodpay will conduct risk assessments on customers to determine their risk profile based on factors such as:

a. Geographic location.

b. Type of business or industry.

c. Nature and volume of transactions.

d. Presence on any sanctions or watch lists.

Ongoing Monitoring

Hoodpay will conduct ongoing monitoring of customer transactions and activities to identify any unusual or suspicious patterns. This monitoring may include:

a. Reviewing transaction history and comparing it to the customer's expected activity.

b. Identifying large or complex transactions that may warrant further investigation.

c. Investigating any sudden changes in the customer's transaction patterns.

High-Risk Customers

Hoodpay will conduct EDD for customers that present a higher risk of money laundering or terrorist financing. Factors triggering EDD may include:

a. Customers from high-risk jurisdictions.

b. Politically exposed persons (PEPs).

c. Customers engaging in high-risk activities or transactions.

EDD Procedures

EDD measures may include:

a. Obtaining additional information about the customer's background, source of funds, and purpose of transactions.

b. Conducting more frequent transaction monitoring and reviews.

c. Requiring senior management approval for high-risk relationships or transactions.

Recordkeeping

Hoodpay will maintain records of customer identification information, transaction history, and other relevant documents for a minimum of five years. These records will be readily available for inspection by regulatory authorities or law enforcement agencies upon request.

Reporting

Hoodpay will file appropriate reports, such as Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs), with FinCEN and other relevant authorities as required by law. The Compliance Officer will ensure that reports are submitted in a timely manner and that all reporting requirements are met.

Employee Training

Hoodpay will provide regular training to its employees to ensure they understand their responsibilities under the AML and CTF compliance program. This training will include:

a. Instruction on relevant laws and regulations.

b. Explanation of internal AML and CTF policies and procedures.

c. Guidance on identifying and reporting suspicious activities.

Training Frequency and Evaluation

Training will be conducted at least annually, or more frequently if necessary due to changes in regulations or the risk environment. Employees will be assessed on their understanding of the training material, and refresher training may be provided as needed.

Audit Scope and Frequency

Hoodpay will conduct periodic independent audits of its AML and CTF compliance program to ensure its effectiveness and compliance with relevant laws and regulations. The audit scope will include a review of policies and procedures, risk assessments, customer due diligence, transaction monitoring, reporting, and employee training.

Audit Findings and Remediation

The results of the independent audit will be reported to Hoodpay's senior management, who will be responsible for addressing any identified deficiencies or areas for improvement. The Compliance Officer will oversee the implementation of any necessary remedial actions and ensure that they are completed in a timely manner.

Hoodpay, LLC

1309 Coffeen Avenue Ste 8393

Sheridan, WY 82801

This policy will be reviewed and updated regularly to ensure ongoing compliance with applicable laws and regulations. Hoodpay is committed to upholding the highest standards of compliance to protect its customers, partners, and the financial system from money laundering, terrorist financing, and other illicit activities.