AML / KYC Statement

1. Our commitment

ZFM Solutions FZCO ("ZFM", "we", "our") operates as a software-as-a-service company providing workflow automation infrastructure to international business customers. While ZFM is not itself a financial institution, money-services business, or licensed financial intermediary, we recognise the importance of maintaining robust anti-money-laundering (AML), counter-terrorist-financing (CTF) and know-your-customer (KYC) standards in our customer onboarding and ongoing monitoring practices.

This statement describes our approach. It applies to all customers of the ZFM platform, all third-party partners and integration providers, and all personnel involved in customer-facing operations.

2. Regulatory framework

ZFM SOLUTIONS - FZCO is incorporated as a Free Zone Company under the laws of the United Arab Emirates, with its registered office at IFZA Business Park, DDP, Premises Number 44754-001, Dubai Silicon Oasis, Dubai, United Arab Emirates. Our AML / KYC framework is designed to align with the following standards, to the extent applicable to a UAE-incorporated technology service provider:

• UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, as amended
• UAE Cabinet Decision No. 10 of 2019 (Implementing Regulation to the AML/CTF Law)
• Recommendations of the Financial Action Task Force (FATF)
• European Union Anti-Money-Laundering Directives, where applicable to EU-based customers
• Sanctions lists maintained by OFAC, the UN, the EU, the UK and the UAE Local Terrorist List

3. Customer due diligence

All business customers of ZFM are subject to a tiered customer due diligence process, sized to the nature of the relationship:

Standard onboarding

• Verification of corporate identity, including legal name, registered address and incorporation jurisdiction
• Identification of ultimate beneficial owners holding 25% or more of the entity
• Validation of the nature and purpose of the customer's use of the ZFM platform
• Screening against international sanctions lists and politically exposed person (PEP) databases

Enhanced due diligence

Applied to customers from higher-risk jurisdictions, those operating in higher-risk industries, or where indicators of unusual activity are present. Includes:

• Source of funds documentation
• Additional ownership and control structure verification
• Senior management approval for the relationship
• Enhanced ongoing monitoring

4. Prohibited activities

ZFM does not knowingly provide services to, or process workflows on behalf of, any entity engaged in:

• Money-laundering or terrorist financing
• Activities subject to applicable sanctions
• Unlicensed financial services activity
• Trade in illegal goods or services
• Human trafficking or modern slavery
• Activities prohibited by UAE law

Customers found to be engaged in any of the above will have their service terminated and, where required by law, reported to the relevant competent authorities.

5. Ongoing monitoring

Our compliance program includes:

• Continuous transaction monitoring of platform usage patterns to identify unusual or potentially suspicious activity
• Periodic re-verification of customer information at intervals proportionate to risk
• Sanctions list re-screening at least monthly
• Incident reporting protocols and a dedicated compliance review process

6. Record keeping

ZFM maintains records of customer due diligence documentation, transaction logs and compliance decisions for a minimum of five (5) years from the end of the customer relationship, or for such longer period as required by applicable law.

7. Reporting suspicious activity

Where ZFM identifies activity that gives rise to reasonable suspicion of money-laundering, terrorist financing or other financial crime, we will submit a Suspicious Activity Report (SAR) to the UAE Financial Intelligence Unit and cooperate fully with any subsequent investigation. We do not disclose the existence or content of such reports to the affected customer.

8. Training and culture

All ZFM personnel involved in customer-facing operations receive AML / KYC awareness training during onboarding and at least annually thereafter. Our compliance function reports directly to senior management.

9. Partner Program payouts

ZFM operates a Partner Program through which third parties — including affiliates, implementation consultants and resellers — earn commission on customer subscriptions they refer or service. These outbound commission payments are integral to our distribution model and are processed through regulated payment service providers such as Payoneer, Wise and traditional banking rails.

Every prospective partner is subject to the following controls before the first payout is released:

• Identity verification, including government-issued ID and proof of address
• Sanctions and PEP screening at onboarding and on a continuous basis
• Tax-form collection (W-8BEN / W-9 / equivalent) where applicable
• Acceptance of the Partner Terms, which include explicit AML and acceptable-use obligations
• Enhanced due diligence for partners in higher-risk jurisdictions or with payout volume exceeding USD 10,000 in any rolling 30-day period

Partner statements are generated by ZFM on a self-billed basis, with full transaction reconciliation against the underlying customer subscriptions. This creates an end-to-end audit trail linking each outbound commission payment to a specific verified inbound subscription event.

10. Cooperation with payment partners

ZFM works with regulated payment service providers, including Payoneer and others, for both the collection of customer subscription fees and the settlement of partner commission payouts. Where requested by such partners as part of their own regulatory obligations, ZFM will provide information sufficient to demonstrate the legitimate business purpose of payment flows — including, on request, partner statements, customer subscription records, and the underlying transaction reconciliation. We expect our payment partners to maintain compliance standards comparable to or higher than the framework described herein.

11. Contact

Questions about this statement, requests for additional documentation, or concerns about possible non-compliance can be directed to:

This statement does not create any legal rights or obligations beyond those established by applicable law and the ZFM Terms of Service. It is provided for informational purposes to demonstrate the seriousness with which ZFM Solutions approaches its compliance responsibilities.