1. Purpose of Policy

This Anti-Money Laundering and Counter-Terrorism Financing Policy (“Policy”) sets out the measures maintained by COSMANX PTE. LTD. (“Company”, “CosmanX”, “we”, “us”, or “our”) to help detect, prevent, investigate, and where required report money laundering, terrorist financing, sanctions breaches, and other unlawful financial activity.

CosmanX seeks to operate in accordance with applicable requirements and guidance issued by the Monetary Authority of Singapore (MAS), relevant sanctions authorities including OFAC where applicable, and internationally recognised standards such as those developed by the Financial Action Task Force (FATF).

2. Risk-Based Approach

CosmanX applies a risk-based approach to AML/CFT compliance. The level of review, monitoring, and screening may vary according to the risk profile associated with a User, merchant, funding source, transaction behaviour, geographic exposure, or merchant category code (MCC).

Users or activities presenting a higher level of risk may be subject to enhanced monitoring, additional verification, or further compliance review.

3. Know-Your-Customer (KYC) Measures

3.1 Identity Verification

Users may be required to successfully complete identity and/or business verification before Virtual Card functionality or other relevant Services can be activated.

3.2 Verification Information

KYC and KYB records may include, where applicable:

• government-issued identity documents;
• business registration certificates or corporate documents;
• proof of residential or business address;
• evidence of advertising activity or legitimate business purpose where required; and
• source-of-funds or related supporting documentation.

3.3 Failure to Provide Information

If a User does not provide information reasonably requested for verification or compliance purposes, onboarding may be delayed, access may be restricted, or the relevant Services may be declined.

4. Ongoing Monitoring

CosmanX may monitor User activity on an ongoing basis to identify unusual, suspicious, or potentially prohibited behaviour.

Monitoring may include review of:

• transaction patterns and spending behaviour;
• transaction decline ratios;
• chargeback frequency;
• unusual, inconsistent, or suspicious MCC activity; and
• geolocation, device, and transaction-velocity indicators.

Activity that appears abnormal or inconsistent with expected use may result in additional review, temporary restrictions, or suspension while an investigation is conducted.

5. Sanctions Compliance

CosmanX does not make Services available where doing so would conflict with applicable sanctions, legal restrictions, or compliance obligations.

Restricted Users or activities may include individuals or entities that are:

• located in or connected with jurisdictions subject to applicable sanctions;
• identified as presenting elevated risk under relevant FATF classifications;
• operating from jurisdictions that do not provide sufficient cooperation or verification standards; or
• otherwise restricted under applicable CosmanX terms, partner requirements, or compliance rules.

Users must not attempt to bypass geographic or sanctions restrictions through sub-accounts, intermediaries, nominees, or third parties.

6. Enhanced Due Diligence (EDD)

Users, businesses, transactions, or activities identified as higher risk may be subject to Enhanced Due Diligence.

Additional review may include:

• business-purpose or business-justification statements;
• verification of advertising platform accounts or related business activity;
• additional transparency regarding expected or actual spending patterns; and
• declarations relating to beneficial ownership or control.

Enhanced Due Diligence may be conducted during onboarding or periodically throughout the User’s relationship with CosmanX.

7. Suspicious Activity Reporting

Where CosmanX identifies activity that may be suspicious or legally reportable, the Company may investigate the matter and, where permitted or required, restrict, block, freeze, suspend, or report the relevant activity.

Information may be provided to appropriate parties, including:

• relevant regulatory authorities, including MAS where applicable;
• card-network or partner risk and compliance teams; and
• law-enforcement or other competent authorities where disclosure is legally required.

To the extent permitted by law, CosmanX is not required to disclose internal investigation procedures, reporting decisions, or confidential compliance information to Users.

8. Record Retention

KYC/KYB records, transaction information, compliance records, and related data may be securely retained for the minimum period required by applicable Singapore law, regulatory guidance, partner requirements, or other applicable legal obligations.

Records may also be retained where reasonably necessary for audits, investigations, regulatory inquiries, disputes, or risk-management purposes.

9. User Responsibilities

Users agree to:

• provide complete, truthful, and accurate information;
• use Virtual Cards and other Services only for legitimate business purposes;
• avoid prohibited or restricted activities and merchant categories;
• promptly provide information reasonably requested for compliance review; and
• cooperate with investigations, verification requests, or risk reviews where required.

Failure to comply with these obligations may result in restrictions, suspension, or termination of Services in accordance with applicable terms and partner requirements.

10. Amendments

CosmanX may revise this AML Policy from time to time to reflect regulatory, compliance, operational, partner, or risk-management changes.

Unless otherwise stated, the updated version will become effective when published on the Platform. Continued use of the Platform after publication constitutes acknowledgement of the revised Policy.

11. Contact

For questions relating to this AML Policy or CosmanX compliance matters, please contact: