Anti-Money Laundering Statement

1. Introduction

NXPR Virtual Commerce Services Ltd ("NXPR") is committed to preventing money laundering, terrorist financing, and other financial crime. This statement outlines NXPR's approach to anti-money laundering (AML) and counter-terrorist financing (CTF) compliance.

2. Regulatory Positioning

NXPR operates as a commercial agent under the exemption set out in Article 3(b) of Directive (EU) 2015/2366 (PSD2). NXPR does not hold client funds and is not a regulated obliged entity under Directive (EU) 2015/849 (4AMLD) and Directive (EU) 2018/843 (5AMLD) in its capacity as a commercial agent.

Notwithstanding this positioning, NXPR applies AML/CTF-aligned controls as a matter of good corporate governance and to support the compliance frameworks of its regulated counterparties.

3. AML/CTF Framework

NXPR's AML/CTF framework includes:

a) Counterparty due diligence on engagements

Counterparties engaged by NXPR, including clients, merchants, and service providers, are subject to documented onboarding and due diligence procedures appropriate to the engagement, including verification of corporate identity, beneficial ownership, and regulatory standing.

b) Sanctions screening

NXPR maintains internal policies prohibiting business relationships or transactions with persons or entities subject to:

• EU Consolidated List of Sanctions
• UN Security Council Sanctions List
• OFAC sanctions, where extraterritorial application applies

c) High-risk jurisdictions

NXPR does not engage with counterparties domiciled in jurisdictions identified as high-risk by the Financial Action Task Force (FATF), including those subject to FATF "call for action" and "increased monitoring" lists.

d) Cooperation with regulated PSPs

All payment processing on NXPR-operated platforms is performed by licensed payment service providers regulated within the EU/EEA. NXPR cooperates with these PSPs in their AML/KYC obligations.

e) Record-keeping

NXPR maintains records of business relationships and material transactions in accordance with applicable record-keeping obligations.

f) Cooperation with regulated counterparties on reporting

Where requested by regulated counterparties, NXPR cooperates in their reporting obligations and in the prevention and investigation of financial crime in accordance with applicable law.

4. Prohibited Activities

NXPR will not engage in or facilitate:

• Transactions involving sanctioned persons or jurisdictions
• Transactions involving proceeds of crime
• Transactions facilitating terrorist financing
• Transactions designed to evade reporting obligations
• Any other activity prohibited by applicable AML/CTF legislation

5. Cooperation with Authorities

NXPR cooperates with law enforcement agencies, regulators, and tax authorities in matters relating to AML/CTF, fraud prevention, and financial crime, in accordance with applicable law.

6. Review and Updates

NXPR reviews its AML/CTF policies and procedures periodically to ensure alignment with evolving regulatory standards and best practices.

7. Contact

Inquiries regarding NXPR's AML/CTF framework may be directed to contact@nxprvirtual.com with the subject line "AML / Compliance Inquiry".