AML / KYC Policy

Bekena operates a cryptocurrency payment gateway. We recognize our responsibility to prevent the use of our platform for money laundering, terrorist financing, or other financial crimes.

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy describes our commitment to compliance and the procedures we follow to detect, prevent, and report suspicious activity.

This policy applies to all Bekena employees, contractors, and merchants using our services.

Before accessing live (production) API capabilities, all merchants must complete our KYC process:

Individual Merchants: - Government-issued photo ID (passport, national ID, or driver's license) - Proof of address (utility bill or bank statement, dated within 3 months) - Description of intended use of the payment gateway

Business Merchants: - Certificate of incorporation or business registration - Proof of business address - Identity verification for beneficial owners with 25%+ ownership - Business description, expected monthly volume, and target market

KYC verification typically completes within 24 hours. We reserve the right to request additional documentation at any time.

We conduct ongoing transaction monitoring to detect suspicious activity:

• Automated screening of wallet addresses against OFAC, UN, EU, and other international sanctions lists• Risk scoring of transactions based on blockchain analytics data• Monitoring for patterns consistent with structuring, layering, or placement of illicit funds• Enhanced monitoring for high-risk jurisdictions and transaction types

Transactions flagged by our monitoring system are reviewed by our compliance team. Confirmed suspicious activity is reported to relevant authorities as required by law.

Bekena does not provide services to entities involved in:

• Activities on OFAC, UN, or EU sanctions lists• Terrorist financing or organizations designated as terrorist groups• Human trafficking or exploitation• Illegal arms dealing• Narcotics trafficking• Fraudulent investment schemes (Ponzi schemes, pyramid schemes)• Unlicensed gambling or financial services where licensing is required

Certain business categories are classified as high-risk and require enhanced due diligence, including but not limited to: money service businesses, cryptocurrency exchanges, iGaming operators, and businesses in FATF high-risk jurisdictions.

Bekena does not process payments involving:

• Entities listed on OFAC's Specially Designated Nationals (SDN) list• Countries subject to comprehensive US, EU, or UN sanctions• Transactions that would cause Bekena to violate applicable sanctions regulations

We use automated sanctions screening tools that check counterparty addresses against current sanctions databases in real time. Blocked transactions are flagged and reviewed by our compliance team.

Where required by applicable law, Bekena files Suspicious Activity Reports (SARs) or equivalent reports with relevant financial intelligence units. We cooperate fully with law enforcement requests that comply with applicable legal process.

Merchants who suspect they have received payments associated with illicit activity should contact [email protected] immediately. Do not process or forward such funds.

Bekena retains records required by applicable AML regulations:

• KYC documentation: 5 years from account closure• Transaction records: 7 years• Suspicious activity reports: 7 years• Correspondence related to compliance matters: 7 years

Records are maintained in a secure format accessible to compliance staff and, where legally required, to regulators and law enforcement.

Bekena maintains an internal compliance program that includes:

• Regular AML/KYC training for all employees with access to financial data• Annual review and update of this policy• Designated compliance officer responsible for implementation• Internal audit of compliance procedures

Our compliance program is designed to meet the requirements of applicable AML regulations and international standards including FATF recommendations.

By using Bekena, merchants agree to:

• Not process payments on behalf of prohibited entities or for prohibited activities• Maintain their own KYC/AML program appropriate for their business type where required by law• Notify Bekena immediately of any suspected AML issues related to transactions processed through our platform• Cooperate with Bekena compliance investigations and information requests• Not use Bekena services to circumvent their own AML obligations

Merchants who violate these obligations may have their accounts suspended immediately and may be reported to relevant authorities.

For compliance inquiries, law enforcement requests, or to report suspicious activity:

Compliance / Legal: [email protected] Response time: Within 48 hours

Law enforcement requests should be sent to [email protected] with proper legal process documentation.