SSHY LTD.

Compliance and Merchant Risk Management

SSHY maintains a compliance-focused framework designed to support responsible payment operations, manage merchant-related risks and promote transparency across supported markets. Our approach combines regulatory registration, risk-based merchant onboarding and transaction monitoring practices to support secure and reliable payment services.

1. Regulatory Registration

SSHY LTD. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB) under registration number M23802826. This registration reflects SSHY’s commitment to maintaining compliance with applicable regulatory requirements and supporting responsible payment operations. The availability of SSHY services may vary depending on applicable local laws, merchant eligibility requirements, and the approval and availability of local banking and payment partners. Services are provided only in supported jurisdictions and approved business scenarios.

2. Merchant Due Diligence

SSHY applies a risk-based merchant onboarding process designed to understand each merchant’s business profile, ownership structure, operational activities and intended payment use cases before establishing business relationships.

Merchant Review Includes:

• KYB Verification

Verification of merchant legal identity, registration information and business documentation.

• UBO Identification

Identification and verification of ultimate beneficial owners and controlling parties.

• Business Activity Assessment

Review of merchant business models, products, services and target markets.

• Website and Product Review

Assessment of merchant websites, platforms and customer-facing business activities.

• Jurisdiction Review

Evaluation of operating countries and applicable regulatory requirements.

• Sanctions and PEP Screening

Screening against applicable sanctions lists and politically exposed person (PEP) databases.

• Adverse Media Screening

Review of relevant public information to identify potential reputational risks.

• Ongoing Merchant Monitoring

Periodic review of merchant information and business activities after onboarding.

3. Transaction Risk Management

SSHY applies automated and manual review processes to monitor transaction activity and identify unusual, prohibited or potentially unauthorized behavior. These controls are designed to support transaction integrity and help manage operational risks.

Risk Management Approach:

• Transaction Monitoring

Review of transaction activities through operational monitoring processes.

• Risk-Based Review

Additional assessment may be applied when transactions or activities require further verification.

• Operational Controls

Internal procedures are maintained to identify and address potential payment risks.

• Compliance Support

Risk management practices are aligned with applicable regulatory and partner requirements.