AML Policy

ANTI-MONEY LAUNDERING POLICY STATEMENT

It is the policy of 1CLICK 2PAY INC. (The “Company”) to comply with the “The Bank Secrecy Act (BSA)” to establish and maintain an effective AML program reasonably designed to prevent money laundering and terrorist financing.

This policy statement is integral part of 1CLICK 2PAY’s Anti-Money Laundering Policy, which includes procedures and personnel responsible for complying with this policy and applicable laws.

1Click 2 Pay Inc. (“the Company”) is a company headquartered in Canada. Company and its subsidiaries (collectively “1Click 2 Pay”) make every effort to remain in full compliance with all applicable anti-money laundering laws, rules and standards in the jurisdictions in which it does business. As required by law, 1Click 2 Pay has designated a Chief Compliance Officer who leads a team of employees oversee 1Click 2 Pay’s anti-money laundering efforts. 1Click 2 Pay has developed and implemented a risk-based anti- money laundering program comprising of

· Written Anti-Money Laundering Policies

· Customer Identification Procedures

· Anti-Fraud Procedures

· Record-Keeping Requirements

· Customer Risk Assessment Procedures

· Sanction Lists Procedures

· 1Click 2 Pay Employees Training Procedures

· On-going Customers’s Activty Procedures

Sanctions Policy

1Click 2 Pay is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. 1Click 2 Pay will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.