KYC

Know Your Customer (KYC) Policy

Know Your Customer 101

KYC policies are required under the Bank Secrecy Act (BSA) of 1970, as amended by subsequent legislation including the USA PATRIOT Act of 2001 (Section 326). These laws, codified under 31 U.S.C. § 5318(l) and regulated by FinCEN (31 C.F.R. § 1020.220), mandate that financial institutions and related entities establish and maintain a Customer Identification Program (CIP) to verify the identity of customers and prevent money laundering, terrorist financing, and other illicit activities. Source is a related entity. As such it, it enforces strict KYC CIP mechanisms to ensure compliance with the applicable laws and there requirements.

Purpose

The purpose of this KYC Policy is to prevent misuse of the Source platform for money laundering, terrorist financing, or other illicit activities. It ensures compliance with applicable laws and regulations.

Scope

This policy applies to all who use the Source platform for sending and receiving payments, and payroll processing.

Customer Identification

Source collects all the following required information to ensure compliance with the Customer Identification Program requirements as set out in 31 C.F.R. § 1020.220/ 31 U.S.C. § 5318(l). We collect:

• your Full legal name
• your Date of birth
• where applicable, your Business Name,
• where applicable, your Business incorporation date,
• where applicable, your Business EIN,
• where applicable, your Business address,
• your address
• your Valid government-issued identification
• your social security number, and
• where applicable, your source of funds.

Verification Procedures

Source verifies each customer's activities using:

1. Government-issued identification documents for identity verification.

2. Government-issued identification documents for address verification.

3. Photo submission for identity verification.

4. Document uploads for Business Authorization verification.

5. Phone numbers for Source account verification, and access.

Ongoing Monitoring

Source will employ ongoing monitoring mechanisms to verify Source account activity. However, Source will not employ arbitrary, or invasive mechanisms to control user activity. Source will detect anamolous user activity, flag them, and your account may be suspended.

Anamolous User Activity

Anamolous user activity includes but is not limited to:

• Attempting muliple failed transactions.
• Increased sending and receiving rate.
• Failed debit actions.
• Disparate pay amount designations.
• Unusual increase in an individual employee's pay designation.
• Unusual increase in paid employees.
• etc.

Our Rationale

We believe financial security, and freedom should be built on trust, and committment to the Platform's stated policy procedures. These KYC policies are not subsequent to or controlled by the "Terms of Service," the "Privacy Policy" or The Learmond Corporation's "Master Terms of Service."

Record Keeping

If your relationship with Source ends, all KYC documentation and verification records will be retained for at least 5 years from the end of the customer relationship.

Non-Compliance

Failure to comply with KYC requirements may result in suspended access to The Platform. If you access to the Platform is suspended for any reason, you will be notified that your account has been suspended for cause.

Review and Updates

This policy will be reviewed annually and updated as necessary to comply with legal and regulatory changes.

Last updated: October 28th, 2025