AML/CFT RED FLAGS IN THE E-PAYMENT INDUSTRY

The e-payment industry is very attractive to criminal activity. This is because it provides the
ability to transfer large amounts of money within few clicks. It is common knowledge that
anonymity is a very important factor in money laundering therefore criminals tend to use the
systems that require minimum personal information.

In order to mitigate the risk of using our Payment System for money laundering, UP should
always follow the AML (Anti Money Laundering) regulations.

Examples include but are not limited to:

o Keeping record of all transactions.

o Monitor transactions performed on its platform with respect to frequency and volume,
of use and amount transferred within a certain time.
o Monitor transaction flows

These last two features complement each other since setting limits will force criminals to split
the transaction into smaller ones, which will be detected by monitoring service.

The integrity of a transaction is as important as that of the persons systems upon which it is
being consummated.