AML Policy

Commitment

UAB FluxPayAI (trading as FluxPay / AlterFlux) maintains a comprehensive AML/CFT programme designed to prevent the use of our payment services for money laundering, terrorist financing, or other financial crime. Our programme is aligned with the requirements of the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, the 6th EU Anti-Money Laundering Directive (AMLD6), and applicable guidance from Lietuvos bankas and the Financial Crime Investigation Service (FCIS).

Key Programme Elements

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures for all merchants
• Know Your Customer (KYC) and Know Your Business (KYB) verification at onboarding
• Ultimate Beneficial Owner (UBO) identification and verification
• Automated and manual transaction monitoring for suspicious activity
• Real-time sanctions screening against EU, UN, OFAC, and national sanctions lists
• Politically Exposed Person (PEP) screening
• Suspicious Activity Report (SAR) filing with FCIS
• Staff training programme with annual AML/CFT certification
• Independent internal audit of AML controls on at least an annual basis
• Designated MLRO (Money Laundering Reporting Officer) with direct board access

Risk-Based Approach

We apply a risk-based approach to all merchant relationships. Each merchant is assigned a risk rating at onboarding based on factors including industry vertical, geography, transaction volumes, and business model. Higher-risk merchants are subject to Enhanced Due Diligence, more frequent reviews, and additional monitoring thresholds. Merchants in prohibited categories are declined at application.

Reporting

Where we identify suspicious activity, we file Suspicious Activity Reports with the Financial Crime Investigation Service (FCIS) of Lithuania in accordance with our legal obligations. We do not inform the subject of any filing. Internal escalation procedures ensure that potential ML/TF indicators are reviewed by the MLRO within 24 hours.