Anti-Money Laundering Program

Purpose and Scope

OPS ONE GROUP (DBA of PVDR GROUP LLC), referred to as "OPS ONE," "we," "us," or "our," is committed to the highest standards of Anti-Money Laundering ("AML") compliance and combating the financing of terrorism ("CFT"). This program is established in accordance with the Bank Secrecy Act ("BSA"), the USA PATRIOT Act, and applicable regulations enforced by the Financial Crimes Enforcement Network ("FinCEN").

As a payment systems advisory and merchant operations firm, OPS ONE facilitates the evaluation, implementation, and optimization of payment infrastructure for businesses. While our role is advisory in nature, we recognize the importance of maintaining robust AML/CFT controls to protect our clients, our partners, and the integrity of the financial system.

AML Compliance Officer

OPS ONE has designated an AML Compliance Officer with full responsibility for the implementation and oversight of this program. The AML Compliance Officer is responsible for:

• Ensuring the firm's AML program is implemented effectively and updated as required
• Overseeing compliance with all applicable BSA/AML regulations
• Filing required reports with FinCEN, including Suspicious Activity Reports ("SARs") and Currency Transaction Reports ("CTRs") where applicable
• Coordinating with law enforcement and regulatory agencies as necessary
• Maintaining records of all AML-related activities and training

The AML Compliance Officer reports directly to senior management and has the authority to take all steps necessary to ensure compliance with this program.

Know Your Customer (KYC) and Customer Due Diligence (CDD)

OPS ONE maintains risk-based procedures for verifying the identity of clients and understanding the nature of their business relationships. Our KYC and CDD procedures include:

Customer Identification Program (CIP)

• Collecting and verifying the identity of all clients, including business name, address, tax identification number, and the identity of beneficial owners
• Verifying information through documentary and non-documentary methods
• Screening all clients against the Office of Foreign Assets Control ("OFAC") Specially Designated Nationals ("SDN") list and other applicable sanctions lists
• Retaining records of identification information for a minimum of five years after the relationship ends

Enhanced Due Diligence (EDD)

For clients presenting higher risk — including those in cash-intensive industries, businesses with complex ownership structures, or those operating in higher-risk geographic areas — OPS ONE applies enhanced due diligence measures. These may include additional identity verification, more frequent monitoring, and senior management approval before establishing or continuing the business relationship.

Risk Assessment

OPS ONE conducts periodic risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our services, client base, and geographic exposure. Risk factors considered include:

• Client Risk: Nature of the client's business, ownership structure, industry type, and geographic location
• Product/Service Risk: Types of payment systems and advisory services provided, including cash discount programs, dual pricing implementations, and POS system deployments
• Geographic Risk: Locations where clients operate, with heightened scrutiny for areas identified as higher risk by FinCEN or FATF
• Transaction Risk: Volume, frequency, and patterns of transactions processed through systems we help implement

Risk assessments are reviewed and updated at least annually, or more frequently when significant changes occur in our business, client base, or the regulatory environment.

Transaction Monitoring and Suspicious Activity Reporting

OPS ONE maintains procedures to detect and report suspicious activity. While our primary role is advisory, we are vigilant in monitoring for indicators of potential money laundering or terrorist financing, including:

• Unusual transaction patterns inconsistent with a client's stated business profile
• Clients who are reluctant to provide required identification or business documentation
• Requests to structure transactions in a manner designed to avoid reporting thresholds
• Transactions involving jurisdictions subject to sanctions or identified as high-risk by FATF
• Rapid changes in transaction volume or business activity without reasonable explanation
• Attempts to use payment systems for purposes inconsistent with the client's stated business

When suspicious activity is identified, the AML Compliance Officer will evaluate the activity and, where appropriate, file a Suspicious Activity Report (SAR) with FinCEN within the required timeframe. All employees are instructed to report any concerns about potentially suspicious activity to the AML Compliance Officer immediately.

OFAC Compliance

OPS ONE screens all clients and associated parties against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List), as well as other applicable sanctions lists maintained by the U.S. Department of the Treasury. Screening is conducted at the time of onboarding and periodically thereafter. In the event of a potential match, the AML Compliance Officer will investigate and take appropriate action, including blocking or rejecting the transaction and filing required reports.

Recordkeeping

OPS ONE maintains records in accordance with BSA requirements, including:

• Customer identification and verification records for a minimum of five years after the account is closed or the relationship ends
• Transaction records for a minimum of five years
• Copies of all SARs filed, along with supporting documentation, for a minimum of five years from the date of filing
• Records of all AML training conducted, including dates, attendees, and materials used
• Correspondence with regulatory agencies and law enforcement

Employee Training

All OPS ONE employees and contractors receive AML training upon hire and at least annually thereafter. Training covers:

• Overview of money laundering and terrorist financing risks in the payment processing industry
• Applicable laws and regulations, including the BSA, USA PATRIOT Act, and OFAC requirements
• OPS ONE's AML policies and procedures
• How to identify and report suspicious activity
• Consequences of non-compliance, including potential criminal and civil penalties
• Updates on emerging risks, typologies, and regulatory changes

Independent Testing and Audit

OPS ONE's AML program is subject to independent testing on a periodic basis, commensurate with the firm's risk profile. Independent testing is conducted by qualified personnel who are not involved in the day-to-day implementation of the AML program. The scope of testing includes an evaluation of the overall adequacy of the AML program, assessment of compliance with applicable regulations, review of suspicious activity monitoring and reporting processes, and testing of KYC/CDD procedures. Findings from independent testing are reported to senior management, and corrective actions are implemented promptly.

Prohibited Activities

OPS ONE will not knowingly provide services to, or maintain business relationships with, any individual or entity that:

• Appears on the OFAC SDN List or any other applicable sanctions list
• Is located in, or conducts business with, a jurisdiction subject to comprehensive U.S. sanctions
• Engages in, or is reasonably suspected of engaging in, money laundering, terrorist financing, or other financial crimes
• Refuses to provide required identification or business documentation
• Operates an unlicensed money services business or engages in unlicensed money transmission

Confidentiality

All information related to suspicious activity reporting, including the existence of a SAR filing, is strictly confidential. OPS ONE employees are prohibited from disclosing the existence of a SAR or any related investigation to the subject of the report or to any unauthorized party. Violation of SAR confidentiality requirements may result in civil and criminal penalties under federal law.

Program Review and Updates

This AML program is reviewed at least annually by the AML Compliance Officer and senior management. Updates are made as necessary to reflect changes in applicable laws and regulations, the firm's business activities and risk profile, findings from independent testing or regulatory examinations, and emerging money laundering and terrorist financing risks and typologies. All material changes to this program are approved in writing by senior management.

Contact

If you have questions about this Anti-Money Laundering Program or wish to report suspicious activity, please contact:

This program has been approved in writing by senior management of OPS ONE GROUP and is maintained in accordance with applicable federal regulations.