KYC/AML POLICY (KNOW YOUR CUSTOMER / ANTI-MONEY LAUNDERING)

Effective Date: December 1, 2025
To Go Transfer FZ LLC, License No. 19520/2025
P.O.Box 4422, Twin Towers, Fujairah Creative City – Media Free Zone, UAE
Email: info@togotransfer.com

1. DEFINITIONS

• Company — To Go Transfer FZ LLC and its payment agents, contractors, and service providers acting under agreements.
• User — any person using the ToGoTransfer service (togotransfer.com), including passengers, carriers (and their representatives, employees, drivers), and corporate clients.
• Agreement — the Terms of Use, Carrier License Agreement, and other valid contracts between the Company and the User.
• Suspicious Transaction — any User action on the platform that may violate applicable laws or is deemed suspicious by the Company.
• PEP (Politically Exposed Person) — a politically exposed individual, as well as their relatives and affiliated persons.

2. INTRODUCTION

2.1. This KYC/AML Policy (“Policy”) is developed in accordance with FATF international standards, UAE legislation, EU directives, UK regulations, and other relevant AML/CTF and sanctions compliance requirements.
2.2. The Policy is public and forms an integral part of all agreements with Users.
2.3. In case of conflict between this Policy and other agreements, this Policy prevails unless otherwise explicitly required.

3. OBJECTIVES OF KYC/AML

• Identify Users and participants of the platform.
• Verify the lawful origin and ownership of funds.
• Prevent involvement of the Company in illegal or suspicious activities.
• Ensure compliance with FATF standards, regulators, and applicable laws.

4. SCOPE

4.1. The Policy applies to all Company employees, contractors, payment agents, carriers, and Users of the ToGoTransfer service.
4.2. It covers all stages of customer interaction: registration, verification, monitoring, detection of suspicious transactions, notification, and blocking.

5. USER GUARANTEES AND OBLIGATIONS

5.1. Each User guarantees:

• lawful origin and right to use funds on the platform;
• accuracy of the information provided during registration and transactions;
• compliance with AML/CTF and sanctions legislation;
• lawful use of the service.

5.2. Each User undertakes to:

• comply with international and national KYC/AML rules;
• refrain from money laundering, terrorist financing, or sanctions evasion;
• promptly provide requested documents and information to the Company.

6. USER IDENTIFICATION

6.1. During registration or use of certain features, the Company may request:

• passport/ID (or equivalent identity document);
• company or sole proprietorship registration documents, beneficial ownership details (for carriers/corporate clients);
• licenses/permits for transport, driver’s license, vehicle documents;
• proof of address/residence or business operations;
• payment details and proof of lawful origin of funds.

6.2. Verification procedures may include automated and manual checks such as:

• sanctions and PEP lists screening;
• fraud and watchlist databases;
• internal fraud detection triggers.

6.3. Users are informed that automated decision-making (e.g., anti-fraud, risk scoring) may apply. Users have the right to object to decisions based solely on automated processing.

7. INDICATORS OF SUSPICIOUS TRANSACTIONS

The Company may classify a transaction as suspicious if:

• the User repeatedly cancels trips disproportionally to completed bookings;
• transactions lack clear economic purpose or sense;
• links to money laundering, terrorism financing, or sanctions evasion are detected;
• the User fails to provide required documents or provides false/forged ones;
• the beneficial owner cannot be established, or proxy persons are used;
• the User or their funds are linked to sanctions or watchlists;
• the service is misused or rules are bypassed.

This list is non-exhaustive. The Company may apply professional judgment to detect emerging risks.

8. MEASURES UPON DETECTION

8.1. Upon detecting suspicious actions, the Company may:

• refuse to process a transaction;
• temporarily or permanently restrict access to the account;
• suspend or cancel payments;
• terminate the agreement with the User;
• report information to law enforcement or competent authorities.

8.2. The Company may withhold reasons for refusal or blocking where prohibited by law or supervisory requirements.
8.3. Inactive accounts (no transactions for over 3 months) may be closed.

9. DATA RETENTION

KYC/AML documents and information are retained for at least 7 years after termination of the relationship with the User, unless longer retention is required by law.

10. RESPONSIBLE OFFICER

10.1. The Company’s Director or an appointed employee (KYC/AML Officer) is responsible for implementation and control of this Policy.
10.2. Contact: info@togotransfer.com.

11. TRAINING

The Company provides regular training for employees and contractors on KYC/AML standards, client identification, detection of suspicious transactions, and sanctions compliance.

12. POLICY UPDATES

This Policy is reviewed and updated regularly in line with legislative changes, regulator recommendations, and emerging risks. The current version is always available on the Company’s website.

13. FINAL PROVISIONS

• Compliance with this Policy is mandatory for all employees and Users.
• Breach of this Policy may result in disciplinary, administrative, and/or criminal liability under applicable laws.