KYB & Customer Due Diligence Policy

This Policy describes how Plaitr onboards business Users. Plaitr is self-custodial: balances live in a Squads smart account owned by the User's business and signed by a Privy wallet the User controls. Plaitr does not hold customer funds and does not hold signing keys. Fiat processing rails (ACH, SEPA, wires, and card issuance when live) are delivered by licensed payment partners under their own licences and programs.

Plaitr performs its own KYB checks on prospective Users before provisioning a wallet or enabling fiat rails, so that access is limited to legitimate businesses that meet Plaitr's acceptable-use standards and each payment partner's onboarding requirements.

Plaitr onboards businesses only. Plaitr does not offer personal accounts and does not maintain custody of customer funds or private keys. Accordingly, Plaitr conducts Know-Your-Business (KYB) due diligence on the entity and its beneficial owners, signatories, and directors. Plaitr does not run a separate consumer KYC program for individual account holders.

• Plaitr:self-custodial platform. Collects KYB information, runs vendor-powered screening and beneficial-ownership checks, provisions a Squads smart account in the User's name, and wires that account into fiat payment partners for the rails the User needs.
• Licensed payment partner(e.g. Bridge, Align, and other regulated counterparties): processes fiat rails (ACH, SEPA, wires, card issuance when live) under its own licence, runs its own KYB program for that regulated activity, and does not take custody of the User's balance.
• Didit:Plaitr's vendor for the beneficial-ownership (UBO) portion of KYB only. Didit identifies and verifies natural persons at or above the 25% threshold and returns a structured UBO record. Didit does not run the full KYB program.
• Jurisdiction-specific KYB:full KYB checks (entity verification, sanctions, PEP, adverse-media, and transaction monitoring) are run by the licensed payment partner covering the User's jurisdiction and currency. The checks a US-corp using ACH sees differ from those a UK Ltd using Faster Payments sees; the partner running that rail is the one running that KYB.

Before referral to a licensed partner, Plaitr collects:

• Legal entity name, jurisdiction of incorporation, and constitutional documents
• Business and tax registration identifiers appropriate to the jurisdiction (e.g. EIN, VAT, TRN, PAN/GSTIN/IEC, UEN, Companies House number)
• Registered address
• Names and identity information for directors, authorised signatories, and beneficial owners
• Ownership structure and UBO declaration
• Website, description of business, target markets, expected volumes, and sample invoices

Plaitr uses Didit for the beneficial-ownership portion of KYB. Didit identifies natural persons who directly or indirectly own or control 25% or more of the entity in line with FATF Recommendation 10 (subject to any stricter local requirement, which prevails), and returns a structured UBO record with document verification for each person identified.

Where a jurisdiction requires a lower threshold, or where the User's ownership structure is opaque, Plaitr collects the additional information manually and escalates for Enhanced Due Diligence before enabling any fiat rail.

Full KYB (entity verification, sanctions and PEP screening, adverse-media checks, and transaction monitoring) is performed by the licensed payment partner covering the User's jurisdiction and currency, under that partner's own regulated program. Requirements vary by rail: a US-corp using ACH is screened by a partner licensed for US MSB activity; a UK Ltd using Faster Payments is screened by a partner authorised by the FCA. Plaitr routes the User to the partner covering their corridor and facilitates document collection.

Plaitr does not substitute its own review for the payment partner's regulated determination on that rail.

Each User is assigned a risk rating of Low, Medium, or High based on industry, geography, ownership complexity, screening outcome, expected volumes, and time in business. Users engaged in activities on the Restricted Businesses List are not referred to partners. Higher-risk Users are subject to Enhanced Due Diligence, which may include additional documentation on source of funds and end-customer relationships.

Plaitr monitors platform activity for consistency with the User's declared business profile. Screening is re-run on list updates. Files are refreshed on a risk-based cadence and upon material change or trigger event. Regulated transaction monitoring on the underlying rails is performed by the licensed partner.

Gating and screening records are retained for a minimum of five years after the end of the User relationship, or longer where required by applicable law.

This Policy is owned by the Plaitr Compliance function and reviewed at least annually, and on material change (new partner, new jurisdiction, new product, or regulatory development).

Questions: compliance@plaitr.com.