Anti-Money Laundering Policy

Taper Payer LLC is committed to preventing financial crimes and maintaining the integrity of the global financial system.

Effective Date: January 1, 2026 · Last Updated: March 2026

AML Compliance Matrix

Governance & Program Structure

AML/CTF Program approved annually
NoIn development – to be approved post-launch
Designated Compliance Officer
Yes
Written AML policies & procedures
Yes
Independent audit (internal or third party)
NoPlanned post-launch

🏦 Banking & Shell Bank Policies

Prohibits relationships with shell banks
Yes
Prevents indirect use of shell banks
Yes

🧑‍⚖️ Risk & Customer Controls

PEP identification & monitoring
Yes
Record retention policies
Yes
AML policies applied across operations
Yes
OFAC sanctioned countries included
Yes

🤝 Outsourcing

Outsource AML components
YesE.g. KYC/AML vendors, API providers, compliance tools

📊 Risk Assessments

Customer Risk Assessment
Yes
Enterprise AML Risk Assessment
YesInitial framework in place
Sanctions Risk Assessment
YesInitial framework in place

🔍 Screening & Monitoring

Screening method
Third-party vendor
Sanctions Lists
✅ UN ✅ OFAC ✅ EU ✅ OFSI ✅ G7 Lists
Additional databases
YesVia third-party compliance providers

🧾 Customer Screening

PEP screening
Yes
Adverse media screening
Yes
Frequency
✅ At onboarding ✅ Ongoing monitoring

🪪 KYC / Customer Due Diligence

Customer identification procedures
Yes
UBO verification
Yes
Assess customer AML practices (if applicable)
Yes
Review high-risk customers
Yes
Update KYC info
Yes
Risk-based transaction profiling
Yes

💳 Transactions & Reporting

Fiat transactions supported
Yes
Regulatory reporting obligations
Yes
Transaction monitoring program
YesRules-based / vendor-supported
Structuring detection
Yes

🔗 Crypto / Blockchain

Blockchain monitoring
YesVia providers like Chainalysis / TRM / equivalent – planned via vendor integration

🎓 Training & Internal Controls

AML training program
Yes
Training records retained
Yes
Communication of AML updates
Yes

Policy Narrative

1. Introduction & Commitment

Taper Payer LLC ("Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy establishes the framework to detect, prevent, and report money laundering, terrorist financing, and other financial crimes. All employees, agents, and partners are required to comply with this policy and all applicable laws and regulations, including the Bank Secrecy Act (BSA) and FinCEN guidelines.

2. Customer Due Diligence (CDD)

We apply a risk-based approach to customer due diligence: • Identity Verification: All customers must provide a valid government-issued ID and proof of address before conducting transactions. • Know Your Customer (KYC): We collect and verify full legal name, date of birth, address, and government ID number. • Enhanced Due Diligence (EDD): High-risk customers, PEPs (Politically Exposed Persons), and customers from high-risk jurisdictions are subject to enhanced scrutiny. • Ongoing Monitoring: Customer accounts and transactions are continuously monitored for suspicious activity.

3. Transaction Monitoring

Taper Payer employs automated and manual transaction monitoring to identify unusual or suspicious activity, including: • Transactions structured to avoid reporting thresholds (structuring/smurfing) • Unusually large or frequent transactions inconsistent with customer profile • Transactions involving high-risk countries or sanctioned entities • Rapid movement of funds with no apparent business purpose • Transactions to/from anonymous or unverified sources Suspicious transactions are escalated to our Compliance Officer for review.

4. Suspicious Activity Reporting (SAR)

When suspicious activity is identified, Taper Payer is required to file a Suspicious Activity Report (SAR) with FinCEN within 30 days of detection. We maintain strict confidentiality regarding SAR filings — customers are never notified that a SAR has been filed. All staff are prohibited from "tipping off" any person who is the subject of a SAR.

5. Sanctions Compliance (OFAC)

Taper Payer screens all customers and transactions against the OFAC Specially Designated Nationals (SDN) list and other applicable sanctions lists. We will not process transactions involving: • Sanctioned countries or territories • Sanctioned individuals or entities • Blocked or prohibited transactions under U.S. Treasury regulations Any matches are immediately blocked and reported to the appropriate authorities.

6. Recordkeeping

In accordance with the Bank Secrecy Act, Taper Payer maintains the following records for a minimum of five (5) years: • Customer identification and verification documents • Transaction records for all transfers over $3,000 • Currency Transaction Reports (CTRs) for transactions over $10,000 • Suspicious Activity Reports (SARs) • All AML training records and risk assessments

7. Employee Training

All employees receive AML/CTF training upon hiring and at least annually thereafter. Training covers: • Recognition of red flags and suspicious activity • Customer due diligence and KYC requirements • Reporting obligations and internal escalation procedures • Sanctions compliance and OFAC screening • Consequences of non-compliance

8. Risk Assessment

Taper Payer conducts an annual enterprise-wide AML risk assessment to identify, evaluate, and mitigate money laundering risks. Risk factors considered include customer risk, product/service risk, geographic risk, and channel risk. Results inform updates to our AML controls and procedures.

9. Contact & Reporting

To report suspected money laundering, fraud, or financial crimes, or for compliance inquiries, contact our Compliance Officer: Email: compliance@taperpayer.com Address: 254 Chapman Rd, Ste 208 #26415, Newark, Delaware 19702 Phone: 1-800-TAPER-PAY This policy is reviewed and updated at least annually or whenever there are material changes in applicable laws, regulations, or business operations. Last Updated: March 2026

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