Anti-Money Laundering Policy

This Anti-Money Laundering (AML) and Sanctions Compliance Policy establishes the framework, procedures, and controls that WizzGift LLC ("Company," "we," "our") implements to prevent the use of our services for money laundering, terrorist financing, sanctions evasion, or other financial crimes.

This policy applies to all employees, contractors, and third-party service providers involved in the operation of WizzGift's gift card retail platform.

WizzGift LLC is a gift card retail company that accepts cryptocurrency as a payment method. Our business model involves selling gift cards from various retail brands to customers who pay using digital currencies such as Bitcoin, Litecoin, and XRP. We do not custody cryptocurrency assets; all crypto payments are processed through licensed third-party payment processors.

WizzGift operates in compliance with applicable U.S. laws and regulations, including but not limited to:

• The Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Office of Foreign Assets Control (OFAC) sanctions programs
• Financial Crimes Enforcement Network (FinCEN) regulations
• Applicable state laws and regulations

The Company has designated a Compliance Officer responsible for implementing and maintaining this AML/Sanctions Compliance Policy. The Compliance Officer's responsibilities include:

• Overseeing the implementation of AML controls
• Ensuring compliance with sanctions requirements
• Reviewing and updating this policy annually or as needed
• Coordinating with third-party compliance service providers
• Investigating suspicious activity and filing reports as required
• Maintaining records of compliance activities

WizzGift conducts ongoing risk assessments to identify and mitigate money laundering and sanctions risks associated with our business activities.

Key risk factors we consider include:

• Customer geographic location
• Transaction volume and patterns
• Cryptocurrency payment methods
• Product types (gift card categories)
• Velocity and frequency of transactions

We mitigate identified risks through:

• Transaction limits
• Geographic restrictions
• Third-party sanctions screening
• Automated monitoring systems
• Enhanced due diligence for high-risk indicators

WizzGift is committed to full compliance with U.S. and international sanctions programs.

We screen all transactions against OFAC's Specially Designated Nationals (SDN) List and other relevant sanctions lists. Our screening procedures include:

• Automated real-time screening through our payment processors
• Blocking transactions from sanctioned jurisdictions
• Periodic review and updates of blocked country lists
• Immediate rejection of transactions with sanctions matches

WizzGift does not provide services to customers located in comprehensively sanctioned countries or regions, including but not limited to:

• Cuba
• Iran
• North Korea
• Syria
• The Crimea, Donetsk, and Luhansk regions of Ukraine
• Any other jurisdictions subject to comprehensive U.S. sanctions

We utilize the following third-party service providers for sanctions compliance:

• Coinbase (licensed cryptocurrency exchange with built-in compliance)
• NOWPayments (payment processor with sanctions screening capabilities)

These providers perform real-time sanctions screening on all cryptocurrency transactions processed through their platforms.

WizzGift implements transaction monitoring to detect potentially suspicious activity.

Our monitoring systems track:

• Unusual transaction volumes or patterns
• Rapid successive transactions
• Transactions just below reporting thresholds
• Transactions from high-risk IP addresses or geolocations
• Cryptocurrency wallet addresses associated with illicit activity

When suspicious activity is detected, we:

• Block or delay the transaction pending review
• Conduct enhanced due diligence
• Escalate to the Compliance Officer
• File Suspicious Activity Reports (SARs) as required
• Maintain records of all suspicious activity investigations

While WizzGift operates as a retail gift card platform with transaction-based controls rather than account-based KYC, we implement appropriate due diligence measures.

Our controls include:

• Per-transaction limits
• Daily/weekly transaction velocity limits
• IP-based geographic restrictions
• Device fingerprinting and fraud detection
• Email verification for order delivery

Enhanced due diligence is triggered for:

• Transactions exceeding specified thresholds
• Patterns indicating structuring
• Transactions from high-risk jurisdictions
• Any other red flags identified through monitoring

WizzGift maintains comprehensive records in accordance with applicable regulations. Records retained include:

• Transaction records (minimum 5 years)
• Customer communications
• Suspicious activity investigation files
• Compliance training records
• Policy documents and updates

All records are stored securely and are available for regulatory examination upon request.

All personnel involved in operations receive AML/Sanctions compliance training upon hire and annually thereafter. Training covers:

• Recognition of suspicious activity
• Sanctions compliance requirements
• Reporting procedures
• Policy updates and regulatory changes

This AML/Sanctions Compliance Policy is reviewed at least annually and updated as necessary to address changes in regulations, business operations, or identified risks. Independent testing of AML controls may be conducted periodically to ensure effectiveness.

For questions regarding this policy or to report suspicious activity, contact the Compliance Officer at:

• Email: compliance@wizzgift.com