Anti-Money Laundering (AML) Policy

VirexaPay is committed to maintaining high standards of integrity and transparency in its business operations. We recognize the importance of preventing money laundering, terrorist financing, fraud, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines the principles and measures adopted by VirexaPay to support a secure and compliant business environment.

VirexaPay applies a risk-based approach when evaluating business relationships, payment activities, and operational risks. Enhanced review procedures may be applied where higher-risk activities, industries, jurisdictions, or transaction patterns are identified.

VirexaPay may conduct appropriate due diligence on prospective merchants, business partners, and service providers before establishing a commercial relationship. Depending on the nature of the relationship and associated risk profile, VirexaPay may request information including but not limited to: • Corporate registration documents • Business ownership information • Website and business activity details • Source of funds information • Additional compliance documentation

VirexaPay may monitor payment activity and transaction patterns for the purpose of identifying suspicious, fraudulent, or potentially unlawful activity. Where unusual activity is detected, VirexaPay reserves the right to request additional information, suspend services, or terminate business relationships where appropriate.

VirexaPay does not knowingly support activities that violate applicable laws, sanctions regulations, or international financial crime standards. The Company reserves the right to decline or terminate relationships involving: • Fraudulent activity • Money laundering • Terrorist financing • Sanctions violations • Identity theft • Other unlawful activities

VirexaPay may retain business records, onboarding documentation, and transaction-related information for a reasonable period in accordance with applicable legal, contractual, and operational requirements.

Where required by applicable law, court order, or lawful regulatory request, VirexaPay may cooperate with relevant authorities and provide information necessary to support the prevention and investigation of financial crime.

This AML Policy may be updated periodically to reflect changes in legal, regulatory, operational, or business requirements.

Questions regarding this AML Policy may be directed to: compliance@virexapay.com Last Updated: May 2026