Legal

AML / KYB Policy

LAST UPDATED · JULY 2026 · DRAFT

DRAFT FRAMEWORK — THIS DOCUMENT IS BEING FINALISED WITH COUNSEL AND IS NOT YET A BINDING VERSION. FOR THE CURRENT OPERATIVE TERMS, CONTACT LEGAL@RIGHTRATES.IO.

1. Policy statement

This section will state RightRates' commitment to preventing money laundering and terrorist financing across every routed flow.

2. Merchant due diligence

This section will describe KYB at onboarding: corporate documents, ownership and control, licensing where applicable, and category review.

3. Ongoing monitoring

This section will cover transaction monitoring, risk tiering, periodic re-review and the triggers for enhanced due diligence.

4. Sanctions screening

This section will set out screening of parties and wallets against applicable sanctions lists before and during the relationship.

5. Reporting and records

This section will describe suspicious-activity escalation, audit-ready event records and retention obligations.

6. Partner alignment

This section will explain how RightRates' controls interlock with those of the approved partners who execute regulated activity.

© 2026 RIGHTRATES™ — ALL RIGHTS RESERVED. RIGHTRATES PROVIDES PAYMENT INFRASTRUCTURE THROUGH APPROVED PARTNERS AND IS NOT A BANK. CAPABILITIES ARE SUBJECT TO COMPLIANCE APPROVAL, MERCHANT CATEGORY AND JURISDICTION.