Hoodpay, LLC ("Hoodpay") is committed to ensuring compliance with all applicable laws and regulations, including those related to economic and trade sanctions administered by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury. Hoodpay has implemented this List of Banned Countries and OFAC Compliance Policy to prevent its services from being used in connection with individuals, entities, or countries subject to economic and trade sanctions.

The purpose of this policy is to establish clear guidelines and procedures for identifying and managing transactions, customers, or business relationships associated with individuals, entities, or countries subject to OFAC sanctions. Compliance with this policy is essential to prevent potential violations of applicable laws and regulations, which could result in significant penalties and reputational damage to Hoodpay.

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 transactions with sanctioned individuals, entities, or countries.

In accordance with OFAC regulations and other applicable laws, Hoodpay is prohibited from engaging in transactions or providing services to individuals, entities, or countries that are subject to economic and trade sanctions. The list of banned countries may change over time due to changes in political circumstances or regulatory requirements. Hoodpay will regularly review and update the list of banned countries to ensure compliance with the latest sanctions programs.

As of the last update of this policy, the list of banned countries includes, but is not limited to:

- Iran

- North Korea

- Syria

- Cuba

- Crimea region

Hoodpay will conduct OFAC screenings of customers, partners, and transactions to ensure compliance with applicable sanctions programs. The OFAC screening process includes:

a. Checking customer and partner information against OFAC's Specially Designated Nationals (SDN) list and other relevant sanctions lists.

b. Monitoring transactions for any direct or indirect involvement with sanctioned individuals, entities, or countries.

c. Implementing appropriate measures to block or reject transactions that involve sanctioned parties or violate applicable sanctions programs.

Hoodpay will maintain records of OFAC screenings, blocked or rejected transactions, and any other relevant documentation related to its compliance with sanctions programs. These records will be retained for a minimum of five years and will be made available for inspection by regulatory authorities or law enforcement agencies upon request.

Hoodpay will provide regular training to its employees to ensure they understand their responsibilities related to OFAC compliance and the handling of transactions involving sanctioned individuals, entities, or countries. This training will include instruction on how to conduct OFAC screenings, identify potential sanctions violations, and report any suspicious activities.

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 the risks associated with sanctioned individuals, entities, or countries.