Anti-Money Laundering (AML) Policy - Payxem

Last updated: 12 April 2026

Entity: LINC GLOBAL HUB INC. (operator of Payxem)

Effective date: 1 January 2026

Last updated: 12 April 2026

1. Purpose

This policy sets out how Payxem prevents, detects, and reports money laundering, terrorist financing, and related financial crime across its platform. It applies to all users, employees, contractors, and partners of Payxem.

2. Our Role and Regulatory Position

Payxem is a technology platform that provides invoicing, payment links, a ledger-based wallet, a digital business card, and a portfolio page. Payxem is not a bank, custodial institution, or licensed payment processor. All payments are executed by third-party providers such as PayPal, Stripe, card processors, and crypto rails, each of which applies its own regulated AML controls.

Payxem operates a risk-based AML program appropriate to its role as a platform layer, focused on user verification, monitoring of platform activity, sanctions screening, and cooperation with the regulated providers and authorities.

3. Policy Statement

Payxem has zero tolerance for the use of its platform to launder money, finance terrorism, evade sanctions, or move the proceeds of crime. We are committed to applying customer due diligence, ongoing monitoring, and timely reporting of suspicious activity.

4. Governance and Responsibility

• A designated Compliance Officer is responsible for this program, its implementation, and its periodic review.
• All staff are responsible for following this policy and escalating concerns to the Compliance Officer.
• Senior management supports and resources the AML program.

5. Customer Due Diligence (KYC)

• Users complete identity verification (KYC) before accessing higher-risk functions such as withdrawals and elevated limits.
• We collect and verify identity information, including legal name, date of birth, country, and government identity documentation where required.
• Enhanced Due Diligence (EDD) is applied to higher-risk users, including additional documentation, source-of-funds questions, and senior sign-off.
• Accounts that fail or refuse verification may be limited, suspended, or closed, and funds may be withheld pending review.

6. Sanctions, Embargoes, and PEP Screening

• Payxem does not knowingly facilitate transactions involving individuals, entities, or countries subject to applicable economic sanctions or embargoes.
• Users and relevant transactions are screened against sanctions and watch lists, and we screen for politically exposed persons (PEPs) on a risk basis.
• Matches are investigated, and confirmed prohibited activity results in account closure and reporting where required.

7. Prohibited Activity

Payxem prohibits, and will act against, use of the platform for:

• Money laundering or structuring transactions to avoid reporting requirements
• Terrorist financing or financing of proliferation
• Fraud, scams, or the movement of criminal proceeds
• Transactions with sanctioned countries, entities, or individuals
• Any activity that misuses the financial system

8. Transaction Monitoring

• Payxem monitors platform activity for suspicious or high-risk patterns, including unusual volume, velocity, structuring, mismatched counterparties, and activity inconsistent with a user’s stated profile.
• We may request additional information or documentation to verify the legitimacy of activity at any time.
• We may delay, restrict, or reject transactions, and place holds, based on risk, compliance, or operational requirements.

9. Suspicious Activity Identification and Reporting

• Staff and automated controls escalate suspected suspicious activity to the Compliance Officer.
• The Compliance Officer reviews escalations and, where appropriate, reports to relevant law enforcement or regulatory authorities and to the affected payment providers.
• Payxem may suspend or terminate accounts and withhold funds pending investigation, and will cooperate with lawful requests from authorities.
• Users are not informed where doing so would constitute unlawful tipping-off.

10. Record Keeping and Retention

• KYC, transaction, and compliance records are retained to meet anti-money-laundering and audit obligations.
• Records relevant to AML and audit are retained for up to 5 years after account closure, with personal identifiers minimized where possible.
• KYC-verified account data is retained in line with our Privacy Policy, and longer where AML obligations require.

11. Risk-Based Approach

Payxem applies controls proportionate to risk, considering user type, geography, transaction size and pattern, and payment method. Higher-risk situations receive enhanced scrutiny, lower-risk situations receive streamlined handling.

12. Training and Awareness

Relevant staff receive AML awareness guidance on identifying and escalating suspicious activity, sanctions obligations, and their responsibilities under this policy.

13. Cooperation with Providers and Authorities

Payxem cooperates with its regulated payment providers and with law enforcement and regulators, including responding to lawful information requests and supporting investigations.

14. Review and Updates

This policy is reviewed at least annually, and after any material change in services, risk, or applicable requirements. Updates are approved by the Compliance Officer and senior management.

15. Contact

AML and compliance enquiries: [email protected]

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