AML Policy

Anti-money Laundering And Identity Verification Policy

Payward, Inc.'s ("Payward" or the "Company") Anti-Money Laundering ("AML") Policy and Identity Verification Policy (collectively the "AML Policy") is designed to articulate Payward's commitment to detecting, preventing and reporting attempts to use its financial services platform to illegally launder money, to finance illegal activities such as terrorism and drug trafficking, or to commit fraud.

Policy

Payward offers a financial services platform through Kraken.com ("Kraken" or the "Service") that allows people to buy, sell and trade currencies, including math-based currencies such as bitcoins and ripples ("exchange services"). Payward also offers, through the Service, a trading platform that allows people to deposit or withdraw funds to and from an account via bank wire transfer, cash deposit at a physical bank teller, third-party gateway, in-game transfer, or direct transfer from third party Bitcoin exchanges. On Kraken, people can buy or sell Bitcoins on the open market, open a long or short position against a currency using deposited funds as leverage, or hold funds indefinitely.

Payward recognizes that decentralized and distributed digital currency and payment systems in which payments are processed and secured by advanced cryptography and distributed computing power instead of a central bank, corporation or government pose a risk of illegal uses (as do all financial systems). Payward believes, however, that the legitimate use of math-based currency networks provide untold benefits and efficiencies within the global economy. Accordingly, Payward has implemented this Policy and its accompanying AML Program to assess the specific risks posed by Payward's innovative services and established specific controls to address those risks as required by law.

It is Payward's policy to comply with applicable laws and regulations regarding AML and identity verification, and to detect and prevent the use of its Service for money laundering or to facilitate criminal or terrorist activities. While Payward is committed to protecting its users' privacy, it will not allow people to use its Services to launder money, commit fraud or other financial crimes, finance terrorist activities, or facilitate other illegal conduct.