AML & Compliance Policy of the BeriPay Service (Operator: NextLab LLC)

Date of Last Update: September 30, 2026

1.1. This Anti-Money Laundering and Compliance Policy (hereinafter, the “AML Policy”) sets forth the core principles, standards, and procedures implemented by NextLab LLC (ООО «НекстЛаб»), Registration No. 326188-3301-ООО, INN 00203202610365, legal address: Office 4a, 141 Toktogula St., Pervomaisky District, Bishkek, Kyrgyz Republic (hereinafter, the “Company”), in operating the BeriPay information technology service (hereinafter, the “Service”).

1.2. The Company strictly complies with the AML/CFT laws of the Kyrgyz Republic, the recommendations of the Financial Action Task Force (FATF), international sanctions frameworks (OFAC, EU, UN, UK), and international card scheme regulations.

2.1. The Company provides Users solely with an information technology interface (SaaS solution) to access services offered by issuing banks and licensed financial partners. The Company is not a bank, credit institution, payment system operator, or Virtual Asset Service Provider (VASP).

2.2. The Service operates strictly under a “Spend-Only” architectural model (strictly non-cash payments for goods and services outside the Russian Federation). The following features are strictly prohibited and technically impossiblewithin the Service:

  • Cash withdrawals via automated teller machines (ATM);
  • Person-to-person funds transfers (P2P);
  • Fund withdrawals from Virtual Cards to Users’ bank accounts, e-wallets, or crypto wallets.

3. Know Your Customer (KYC/CDD) and Identity Verification

3.1. The Company applies a Risk-Based Approach (RBA) when carrying out Customer Due Diligence (CDD) procedures.

3.2. User verification (KYC) is conducted by the Company with the engagement of specialized accredited identity verification and compliance analytics partners. The verification procedure may include:

  • Identity Verification: Verification of the authenticity of a passport or national ID card;
  • Biometric Verification: Facial recognition checks (Liveness check / 3D Face Map) to prevent identity impersonation;
  • PEP Screening: Checking for Politically Exposed Persons status, including family members and close associates;
  • Sanctions Screening: Screening against global sanctions databases (OFAC, EU, UN, UK, HMT) and watchlists for terrorism and extremism.

3.3. The Company reserves the right to request Enhanced Due Diligence (EDD) upon any change in a User’s risk profile or detection of anomalous transaction patterns.

4. Transaction Monitoring and Suspicious Activity (Red Flags)

4.1. All transactions processed via the Service are subject to ongoing automated and manual compliance monitoring to identify suspicious activity.

4.2. Suspicious Activity Indicators (Red Flags):

  • Refusal to provide requested verification documents or submission of altered/falsified data;
  • High-frequency transactions for identical amounts within short time intervals (Structuring / Splitting);
  • Attempts to process payments to high-risk, unauthorized, or prohibited merchants;
  • Use of anonymizers, compromised VPN/PROXY services, or location mismatches between IP address and registration details;
  • Initiation of unsubstantiated payment disputes or chargebacks (Friendly Fraud).

5. Acceptable Use Policy (AUP / Prohibited Activities)

It is strictly forbidden to use Virtual Cards or Service features to pay for or fund:

  • Illicit trade in narcotics, weapons, ammunition, or hazardous materials;
  • Unlicensed online gambling, illegal casinos, or unauthorized sports betting;
  • Ponzi schemes, HYIP programs, or unregistered investment products;
  • Adult content violating applicable local laws, or counterfeit goods;
  • Any activities aimed at circumventing international trade or financial sanctions.

6. Asset Freezing, Account Suspension, and Appeals

6.1. Upon detection of suspicious activity, sanctions matches, or upon request of issuing partners, the Company and/or issuing partner reserves the right to immediately and without prior notice:

  • Block the User’s Account and restrict access to the Service;
  • Suspend or cancel issued Virtual Cards;
  • Reject top-up requests or payment authorizations.

6.2. Disclaimer Regarding Frozen Funds: The Company has no direct legal or technical access to funds held in frozen partner accounts or issuer cards. Unblocking and appeal procedures are governed by the rules of the issuing partner, with informational support from the Company.

7. Record Keeping and Regulatory Reporting

7.1. In accordance with international AML standards, the Company and its accredited KYC partners retain all customer identification data, document copies, and transaction records for at least 5 (five) years following the termination of the business relationship.

7.2. The Company reserves the right to report suspicious transactions and individuals involved in unlawful acts to authorized government bodies and financial intelligence units (FIUs) as required by applicable law.

8. Compliance Contacts

For compliance, verification, and AML inquiries: