Overview Feedzai’s Trade Sanctions and AML Policy

Feedzai Group is committed to compliance with applicable trade sanctions and export controls (Sanctions), and anti-money laundering (AML) laws. The Trade Sanctions and AML Policy (full text is Company-Private and not publicly available) applies to all individuals associated with Feedzai and outlines strict adherence to various laws, including U.S., EU, and UN sanctions, and more. It extends its reach to agents, representatives, and business partners.

The policy specifically addresses Sanctions, including the U.S. Office of Foreign Assets Control’s (“OFAC”) various country-based, list-based, and sectoral sanctions programs. The Policy restricts transactions involving sanctioned countries or persons designated to OFAC or other applicable government restricted parties lists.

To ensure compliance, Feedzai implements a Know Your Customer (KYC) procedure for screening clients and business partners, and a Know Your Vendor (KYV) procedure for screening its service providers, against OFAC lists and other restricted party lists, promoting adherence to legal requirements.

The Policy also covers AML, emphasizing the importance of engaging only with reputable and legitimate clients, business partners, and service providers to avoid any association with illegal activities.

Reporting mechanisms for suspicious transactions are established, encouraging the report of any actual or suspected AML violations through the Feedzai Hotline, ensuring confidentiality and protection against retaliation for those acting in good faith.

The Policy mandates compliance procedures and training programs for employees, promoting a thorough understanding of the requirements and obligations of Sanctions and AML Laws. The Compliance Officer oversees the Policy’s implementation.

In a nutshell, the policy reflects Feedzai’s commitment to legal and ethical business practices, setting clear expectations for compliance with applicable -Sanctions and AML laws across all facets of its operations.