IS Pay maintains a written AML/BSA Compliance Program per 31 U.S.C. § 5318(h) and 31 CFR 1022.210. The program covers all five BSA pillars and is reviewed annually or upon material change to the business model.

⚠ No client may receive IS Pay services without completed and approved KYC/KYB verification. No exceptions.

The Compliance Officer reviews the Transaction Ledger daily. The following patterns trigger mandatory investigation:

For all payment mandates of $3,000 USD or more, IS Pay collects and retains originator and beneficiary information per the BSA BSA Recordkeeping Compliance.

IS Pay maintains a Prohibited Activities Policy that is enforced at onboarding and on an ongoing basis. The following activities and client types are categorically prohibited — no exceptions.

IS Pay maintains the following active controls across all payment mandate operations. These controls are applied at onboarding, pre-execution, and on an ongoing basis.

IS Pay is not seeking a product. IS Pay is offering a distribution network. The partnership model is straightforward:

IS Pay provides payment execution, cross-border payout coordination, contractor and vendor payment support, and related financial technology services.

IS Pay provides technology-enabled payment execution and settlement coordination services for businesses, independent contractors, freelancers, marketplaces, and approved commercial users. Services may include:

• Domestic and international payout coordination
• Contractor and vendor payment execution
• Payment orchestration services
• Stablecoin-enabled settlement support
• Treasury and payout infrastructure coordination
• API and embedded payment integrations
• Cross-border payment support through authorized third-party providers

IS Pay may utilize regulated banking partners, payment processors, stablecoin infrastructure providers, compliance vendors, and other authorized third-party service providers to facilitate services.

IS Pay is not a bank and does not provide deposit accounts.

To use IS Pay services, you must:

• Be at least 18 years old
• Have legal capacity to enter into binding agreements
• Comply with all applicable laws and regulations
• Successfully complete applicable identity verification procedures
• Not be subject to sanctions or prohibited-party restrictions

Business users may be required to complete KYB (Know Your Business) verification.

IS Pay maintains compliance procedures designed to support anti-money laundering (AML), sanctions compliance, fraud prevention, and regulatory obligations. Users may be required to provide:

• Government-issued identification
• Business formation documents
• Proof of address
• Source of funds information
• Invoices, contracts, or supporting documentation
• Additional compliance information upon request

IS Pay reserves the right to deny, suspend, restrict, or terminate services based on compliance, legal, operational, or risk-related considerations.

Users may not use IS Pay services for:

• Illegal activity
• Fraud or deceptive practices
• Money laundering
• Terrorist financing
• Sanctions evasion
• Unauthorized money transmission
• Darknet-related activity
• Gambling where prohibited
• Human trafficking or exploitation
• Unauthorized investment schemes
• Intellectual property violations
• Any activity prohibited by applicable law

IS Pay reserves the right to monitor activity and report suspicious activity where legally required.

IS Pay may rely on third-party infrastructure providers, including banking partners, payment processors, stablecoin infrastructure providers, identity verification vendors, compliance vendors, and settlement partners.

Certain services may be subject to additional terms and policies from such providers. IS Pay does not guarantee uninterrupted availability of third-party infrastructure.

Certain services may involve stablecoin-enabled settlement infrastructure or blockchain-based payment coordination. Users acknowledge that:

• Digital asset transactions may involve regulatory uncertainty
• Blockchain settlement may experience delays
• Stablecoin issuers and infrastructure providers operate independently from IS Pay
• Network congestion or technical disruptions may occur
• Regulatory treatment of digital assets may change

IS Pay does not provide investment advice, custody services, or speculative trading services.

IS Pay is not a bank, depository institution, or investment adviser. Use of IS Pay services does not create:

• A bank account
• A deposit relationship
• FDIC insurance coverage through IS Pay
• A custodial account relationship unless expressly stated by an authorized partner provider

IS Pay may charge service fees, processing fees, payout fees, conversion fees, or other applicable fees. Applicable fees may be disclosed through agreements, invoices, onboarding materials, or platform interfaces.

IS Pay reserves the right to suspend, limit, or terminate access to services at any time for:

• Compliance concerns
• Regulatory requirements
• Fraud prevention
• Risk management
• Violation of these Terms
• Operational or security reasons

To the maximum extent permitted by law, IS Pay shall not be liable for:

• Indirect or consequential damages
• Loss of profits
• Delays caused by third-party providers
• Blockchain or network failures
• Regulatory actions
• Service interruptions
• Data loss beyond reasonable control

IS Pay's total liability shall not exceed the fees paid to IS Pay related to the specific service giving rise to the claim.

You agree to indemnify and hold harmless IS Pay, its affiliates, officers, employees, and partners from claims, damages, liabilities, losses, and expenses arising from:

• Your use of services
• Violation of these Terms
• Violation of law
• Fraudulent or unlawful conduct

These Terms shall be governed by the laws of the State of Florida and applicable United States federal law.

We may collect the following categories of information:

• Full name
• Email address
• Telephone number
• Residential or business address
• Government-issued identification
• Date of birth
• Biometric data collected during identity verification procedures (facial recognition, liveness detection), where required by our verification providers

• Company name
• Employer Identification Number (EIN)
• Ownership and control information
• Corporate formation documents
• Business activities and supporting documentation

• Payment instructions
• Transaction records
• Account activity
• Risk and compliance information

• IP address
• Browser type
• Device information
• Cookies and analytics data

We use collected information to:

• Provide and improve our services
• Verify customer identities
• Conduct KYC/KYB procedures
• Comply with AML, BSA, OFAC, and other legal requirements
• Detect fraud and financial crime
• Communicate with customers
• Respond to inquiries and support requests
• Maintain platform security

We may share information with trusted third-party providers, including:

• Identity verification and biometric screening providers
• Sanctions screening and watchlist providers (including OFAC SDN, UN, EU, and HMT sanctions lists)
• Compliance and adverse media screening providers
• Banking partners
• Payment infrastructure partners
• Regulatory authorities when legally required

Such disclosures are limited to what is reasonably necessary to provide services and satisfy compliance obligations.

Certain information collected through our compliance processes may be subject to confidentiality obligations under federal law. Pursuant to 31 U.S.C. § 5318(g)(2), IS Pay is legally prohibited from disclosing the existence, content, or consideration of any Suspicious Activity Report (SAR) filed with the Financial Crimes Enforcement Network (FinCEN), or any related compliance investigation, to any customer, agent, or third party except as expressly permitted by law. This prohibition is absolute and applies regardless of the circumstances under which a customer relationship is modified or terminated.

We retain information for as long as necessary to:

• Provide services
• Meet legal and regulatory obligations, including a minimum of five (5) years as required under 31 CFR 1010.430 (Bank Secrecy Act recordkeeping requirements)
• Resolve disputes
• Enforce agreements

Retention periods may extend beyond account closure where required by law.

We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction.

However, no internet transmission or storage system can be guaranteed to be completely secure.

Our website may use cookies and similar technologies to:

• Improve user experience
• Analyze website performance
• Maintain security
• Understand visitor behavior

Users may adjust browser settings to manage cookies.

IS Pay operates from the United States and processes information through service providers and infrastructure partners operating across multiple jurisdictions, including the United States, Colombia, European Union member states, Chile, Mexico, and other markets where IS Pay provides payment services. Information may be transferred to and processed in these jurisdictions.

Where required by applicable law, appropriate safeguards will be implemented to protect information transferred across borders, including standard contractual clauses or equivalent mechanisms.

Depending on applicable law, users may have rights to:

• Access personal information
• Correct inaccurate information
• Request deletion where legally permissible
• Object to certain processing activities

Residents of the European Union or European Economic Area may have additional rights under the General Data Protection Regulation (GDPR), including the right to data portability, the right to restriction of processing, and the right to lodge a complaint with a supervisory authority.

Requests may be submitted through the contact information below. IS Pay will respond within a reasonable time and in accordance with applicable law. Certain requests may be subject to legal limitations, including mandatory retention obligations under the Bank Secrecy Act and other applicable regulations.

Our website may contain links to third-party websites. We are not responsible for the privacy practices of external sites.

We may update this Privacy Policy periodically. Updates become effective upon posting on our website. Material changes will be communicated where required by applicable law.

Services are available exclusively to legally authorized business entities and independently verified professional service providers operating for documented commercial purposes. IS Pay does not offer services to individual consumers. Services are limited to approved B2B commercial use cases.

Users must:

• Be a legally constituted business entity or verified professional counterparty
• Provide accurate, complete, and current information
• Comply with all applicable laws in their jurisdiction of operation
• Complete all verification requirements when requested
• Have a documented commercial purpose for each transaction

IS Pay provides B2B cross-border payment coordination services, financial technology solutions, and related business services through its own systems and authorized third-party partners.

IS Pay coordinates compliant cross-border settlement workflows for verified business clients. IS Pay is a financial technology company, not a bank, and does not accept consumer deposits, maintain stored client balances, or offer investment products. All services are executed through regulated third-party financial infrastructure providers.

Service availability may vary by jurisdiction and regulatory requirements.

IS Pay requires all clients to complete KYC/KYB verification prior to accessing any service. No service will be provided without completed and approved verification.

IS Pay may require:

• Identity and business entity verification
• Beneficial ownership documentation
• Source of funds documentation
• Signed Payment Services Agreement
• Additional compliance information at any time

Failure to provide requested information may result in service restrictions or termination.

Users acknowledge that IS Pay maintains compliance procedures including:

• Anti-Money Laundering (AML) / Bank Secrecy Act (BSA) compliance
• Know Your Customer (KYC) and Know Your Business (KYB) verification
• OFAC and sanctions screening
• PEP and adverse media screening
• Fraud prevention and transaction monitoring controls

IS Pay may delay, reject, suspend, or terminate transactions at any time when required by law, compliance obligations, or risk management policies, without obligation to disclose the reason.

Each transaction requires a signed Payment Mandate submitted by the client specifying the beneficiary, amount, currency, and documented commercial purpose. IS Pay will not execute any transaction without a valid, approved Payment Mandate. IS Pay reserves the right to reject any Payment Mandate at its sole discretion without disclosure of reason.

Users may not use IS Pay services for:

• Illegal activities of any kind
• Fraudulent conduct or misrepresentation
• Money laundering or structuring
• Terrorist financing
• Sanctions evasion
• Consumer remittances or retail personal transfers
• Cash transactions of any amount
• Anonymous or undocumented transfers
• Transactions involving FATF blacklisted jurisdictions
• Gambling, adult content, darknet, or controlled substance industries
• Unauthorized financial services or pass-through activity

IS Pay reserves the right to investigate, report, and take action on suspicious activity.

Pursuant to 31 U.S.C. § 5318(g)(2), IS Pay is legally prohibited from disclosing the existence, content, or consideration of any Suspicious Activity Report (SAR) filed with FinCEN, or any related compliance investigation, to any customer, agent, or third party except as expressly permitted by law. This prohibition is absolute. Users expressly waive any claim arising from the suspension, restriction, or termination of services where such action is connected to compliance or regulatory reporting obligations.

Certain services are supported by regulated financial institutions, banking partners, payment processors, compliance providers, identity verification providers, and other regulated infrastructure providers. Additional terms from such providers may apply. IS Pay is not responsible for the acts or omissions of third-party providers operating within their own regulated frameworks.

Applicable fees will be disclosed separately through agreements, service schedules, invoices, or customer onboarding documentation. IS Pay reserves the right to modify its fee structure with reasonable prior notice.

IS Pay may suspend or terminate access to services at any time, with or without prior notice, where:

• Compliance concerns exist
• Risk management requires action
• Information provided is inaccurate or incomplete
• Applicable laws or regulations require restriction
• Suspicious activity is identified or reported

Termination for compliance-related reasons is subject to the confidentiality obligations described in Section 7.

Services are provided on an "as available" and "as is" basis. IS Pay makes no guarantee that services will be uninterrupted, error-free, or available at all times. Settlement times referenced in any IS Pay materials are targets, subject to compliance review and banking cut-off times, and are not guaranteed.

To the maximum extent permitted by law, IS Pay shall not be liable for indirect, incidental, special, consequential, or punitive damages arising from use of the services, including but not limited to delays in settlement, rejection of payment mandates for compliance reasons, interruptions in service availability, or changes in corridor or partner availability.

IS Pay's total cumulative liability to any user shall not exceed the total fees paid by that user to IS Pay during the ninety (90) calendar days preceding the event giving rise to the claim.

Users agree to indemnify and hold harmless IS Global Services, LLC, its officers, employees, contractors, affiliates, and partners from any claims, damages, losses, or costs arising from misuse of services, violation of these Terms, provision of inaccurate information, or failure to comply with applicable laws.

These Terms shall be governed by the laws of the State of Florida, United States, without regard to conflict of law principles.

Any dispute arising from or related to these Terms shall first be subject to good faith negotiation between the parties for a period of thirty (30) days. If unresolved, disputes shall be submitted to binding arbitration before the American Arbitration Association (AAA) under its Commercial Arbitration Rules, seated in Orange County, Florida. The arbitral award shall be final and binding.

IS Pay may update these Terms at any time. Material changes will be communicated with reasonable prior notice where practicable. Continued use of services following posted updates constitutes acceptance of the revised Terms.

IS Pay maintains compliance procedures designed to support:

• Anti-Money Laundering (AML)
• Counter-Terrorist Financing (CTF)
• Sanctions compliance
• Fraud prevention
• Risk management
• Regulatory cooperation

• Identity verification (KYC)
• Business verification (KYB)
• Beneficial ownership review
• OFAC and sanctions screening
• Transaction monitoring
• Enhanced due diligence
• Source of funds review

IS Pay reserves the right to:

• Request additional information
• Restrict or reject transactions
• Suspend or terminate services
• Report suspicious activity where required by law

Users must comply with all applicable laws and regulations.

Compliance inquiries: [email protected]

Users may not use IS Pay services for:

• Illegal transactions
• Fraudulent activity
• Sanctions evasion
• Unauthorized money transmission
• Terrorist financing
• Ponzi or pyramid schemes
• Gambling where prohibited
• Darknet activity
• Human exploitation
• Counterfeit goods
• Intellectual property violations
• Unlicensed financial activity
• Deceptive or misleading conduct

IS Pay may investigate activity and take appropriate action where violations are identified, including transaction blocking, account suspension, account termination, and reporting to relevant authorities where required by law.

To report suspected misuse of IS Pay services, contact [email protected].

Users acknowledge that risks may include:

• Regulatory changes
• Delays in settlement
• Third-party provider disruptions
• Stablecoin or blockchain network risks
• Cybersecurity risks
• Compliance-related restrictions
• Currency conversion fluctuations
• International payment delays

IS Pay does not guarantee uninterrupted availability of services. Users are responsible for evaluating risks associated with their use of services.

IS Pay does not provide legal, tax, accounting, or investment advice. Users should consult qualified professionals before making financial, regulatory, or operational decisions based on the use of IS Pay services.

Questions regarding risk disclosures: [email protected]