General Provision

BoxCharge (from now on – the company or BoxCharge) is a provider of technical processing services.

The company shall conform to the local Acts’ requirements on Prevention of Money Laundering and Terrorism Financing and the requirements of other laws and regulations to the extent in which they relate to BoxCharge’s operations.

The company shall strictly comply with the policies and procedures outlined in this document (hereafter – the policy).

BoxCharge develops this policy and may introduce amendments and additions to it at its own volition and oversee compliance with its provisions and requirements.

The client shall read the Policy before accepting BoxCharge’s Terms and Conditions. The client’s consent to the Terms and Conditions, as well as making transactions in the BoxCharge system after accepting the Terms and Conditions, shall signify the client’s acceptance of all the current version provisions of this Policy.

Compliance Officer

To oversee and execute the procedures contemplated in the Policy, BoxCharge appoints a Compliance Officer.

The Compliance Officer is liable for the collection, analysis, and investigation of information on any suspicious actions and the practice of the company’s employees pertaining to the relevant procedures. The Merchant Services Officer shall determine the guidelines and rules for carrying out customer identification, reviewing and monitoring unusual transactions, and technical features of BoxCharge’s implementation of this Policy.

Customer Identification Policy

For client identification, BoxCharge requests the following documents:

• Articles of Incorporation

• Registration certificate (certificate of incorporation)

• Company’s shareholders charter

• Document confirming the authority of the person authorized to act on the company’s behalf

• Proof of identity (passport, driver’s license, national ID card)

• Proof of address (bank statement, utility bill)

• Utility bill

• Good-standing letter

Know Your Customer Verification Procedure

BoxCharge conducts KYC (Know Your Customer) verification procedures to mitigate legal risks and protect itself from illegal activities by clients.

BoxCharge evaluates transactions and stores essential data related to customers and their transactions as part of the KYC process.

After completing client identification, BoxCharge retains all data in the client’s file and is obligated to perform this process only once per client.

BoxCharge commits to safeguarding client rights and personal data. Personal information is collected solely for providing services and disclosed only in limited cases permitted by law and the agreement with the client.

BoxCharge maintains customer files—including statements, transaction reports, notes, and correspondence—in electronic format for as long as required by relevant acquiring banks or processors.

Identification and Detection of Suspicious Activities

Any transaction potentially related to money laundering shall be treated as suspicious.

Suspicious activity may be identified based on employee observation, prior experience, or third-party information.

The Merchant Services Officer shall continuously monitor and update the system to detect suspicious activity.

As per applicable laws and international requirements, BoxCharge may report suspicious transactions to relevant authorities without notifying the customer.

BoxCharge consults local and international lists of known terrorists, high-risk countries, and OFAC-sanctioned jurisdictions to determine whether any customer or their country falls under suspicion.

BoxCharge conducts ongoing due diligence and transaction scrutiny to ensure they align with its knowledge of the customer’s business and, where necessary, the source of funds.

Third-Parties

To perform business functions, BoxCharge may engage third-party service providers.

During due diligence, BoxCharge will determine if such providers have any investigations, lawsuits, or required licenses before forming a partnership.

Regarding internal staff, BoxCharge carefully screens candidates to ensure their role does not pose a money laundering risk and provides training on customer identification and anti-money laundering compliance.

Civil and Criminal Penalties

Governments and international bodies may impose severe civil and criminal penalties on anyone violating laws covered in Section 1.2 of this Policy. These can include significant fines or imprisonment. Property, bank accounts, or business assets involved in violations may be seized.

Companies may be held criminally responsible for their employees’ actions. Corporate clients must ensure their staff are well-informed and comply with relevant laws and regulations.

Compliance Statement

The Corporate Client (or their authorized representative) confirms they have read and understood this notice and agree to operate in full compliance with the Policy and all relevant laws and regulations.

The Corporate Client accepts responsibility for their actions and acknowledges the legal consequences of failing to comply with the provisions of this Policy.