Anti-Money Laundering & Terrorist Financing Compliance Statement

PoaPay LLC. d/b/a PoaPoay Financial Services (the "Company") is licensed as a money transmitter in each state jurisdiction where the company is conducting business. The Company is also registered as a "money services business" ("MSB") with the federal Financial Crime Enforcement Network ("FinCEN").
It is the policy of the Company to provide financial services, including money transfer services and any ancillary services, in accordance with applicable federal and state laws, consistent with an emphasis on safety and soundness. In providing such services, it is the express policy of the Company to comply with all applicable anti-money laundering and terrorist financing laws and regulations, including, but not limited to, the Bank Secrecy Act ("BSA") and the USA PATRIOT Act of 2001, and applicable state laws and regulations.
As a licensed and registered money transmitter, the Company has adopted a comprehensive Bank Secrecy Act/Anti-Money Laundering ("BSA/AML") compliance program. Our compliance program includes written policies and procedures, an appointed compliance officer, agent due diligence procedures, an employee and agent training program, and a periodic independent examination function.
Money laundering and financial crime causes incalculable harm to individuals and the U.S. economy, and undermines confidence in the financial services industry. The war against money laundering and financial crime requires constant vigilance and the commitment of all financial institutions. The Company is fully committed to these efforts. It is the policy of the Company to maintain an effective and robust BSA/AML compliance program.
Some of the elements of our BSA/AML program include:

- Reporting of suspicious customer and agent activities
- Reporting of large currency transactions as required by law
- Agent due diligence and transaction monitoring
- Know Your Customer ("KYC") and Customer Identification Program ("CIP")
- Office of Foreign Assets Control ("OFAC") screening

It is the Company's policy that no customer or agent relationship is worth compromising our integrity and commitment to combating money laundering, terrorist financing and other financial crime. The Company is committed to the highest of standards of BSA/AML compliance and we require that our agents and employees likewise adhere to these standards in preventing our services from being used to facilitate money laundering, terrorist financing and other financial criminal activity.

For additional resources on BSA/AML compliance, go to:
http://www.fincen.gov
http://www.fincen.gov/statutes_regs/guidance
http://www.irs.gov/Businesses/Small-Businesses-&-Self-Employed