Compliance, KYC & Anti-Money Laundering (AML) Policy

1. Introduction

Meeky Cart is committed to maintaining a secure, transparent, and compliant environment for customers, users, affiliates, merchants, suppliers, service providers, and other participants who use our Platform and services.

This Compliance, Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy establishes the principles and procedures that Meeky Cart applies to help prevent and detect:

• • Money laundering;
• • Terrorist financing;
• • Fraud;
• • Identity theft;
• • Payment fraud;
• • Financial crime;
• • Sanctions violations;
• • Prohibited transactions;
• • Account abuse;
• • Misuse of payment instruments;
• • Proceeds of criminal activity; and
• • Other unlawful or suspicious activities.

This Policy applies to the Meeky Cart website, applications, accounts, checkout services, payment-related services, affiliate systems, voucher services, gift card and reloadable card services, eSIM services, phone unlocking services, global fulfillment activities, promotional systems, loyalty programs, and any other services introduced by Meeky Cart from time to time.

Meeky Cart's compliance obligations may vary depending on the nature of a particular service, the jurisdiction involved, the identity of the contracting entity, the payment method used, and applicable laws and regulations.

Where a particular service is provided by a regulated third-party financial institution, payment provider, card issuer, telecommunications provider, or other regulated partner, that provider's regulatory requirements and terms may also apply.

2. Primary Operating Jurisdiction

Meeky Cart's principal operating presence for purposes of this Policy is South Africa.

The entity responsible for a particular transaction or service may depend on the customer's location, the service purchased, the payment method, contractual arrangements, and applicable law.

3. Purpose of this Policy

The purposes of this Policy are to:

• Protect Meeky Cart and its customers from financial crime;
• Establish procedures for identifying customers and users where appropriate;
• Verify customer information where necessary;
• Identify unusual or suspicious activity;
• Prevent unauthorized use of accounts and payment instruments;
• Comply with applicable AML, KYC, sanctions, fraud-prevention, consumer-protection, data-protection, and financial-crime requirements;
• Protect payment and financial systems from misuse;
• Establish procedures for escalating potentially suspicious activity;
• Protect Meeky Cart's business partners and service providers;
• Maintain appropriate records;
• Cooperate with lawful requests from competent authorities; and
• Maintain appropriate risk-based controls as Meeky Cart's services develop.

4. Scope of Application

This Policy may apply to: Customers, Website visitors, Registered account holders, Gift card users, Reloadable card users, Voucher users, Affiliates, Merchants, Business customers, Corporate customers, Suppliers, Service providers, Payment partners, Resellers, Agents, Contractors, Technology partners, and Other persons or entities interacting with Meeky Cart.

The level of verification and monitoring applied may vary according to the risk associated with the particular user, transaction, product, service, jurisdiction, payment method, and activity. Not every customer will necessarily be required to complete the same level of KYC verification.

5. Risk-Based Compliance Approach

Meeky Cart applies a risk-based approach to compliance. This means that the Company may apply different levels of verification, monitoring, review, and documentation depending on the circumstances.

Factors that may influence the level of review include:

Meeky Cart may apply enhanced controls where the perceived risk is higher.

6. Know Your Customer (KYC)

KYC refers to processes used to establish and verify the identity of customers and, where appropriate, businesses or other persons using Meeky Cart services.

Depending on the service and circumstances, Meeky Cart may request information including:

• Full legal name, Date of birth, and Residential address;
• Email address and Telephone number;
• Nationality and Country of residence;
• Government-issued identification and Proof of address;
• Business registration information and Tax information where applicable;
• Payment information and Beneficial ownership information;
• Source-of-funds information and Source-of-wealth information where appropriate; and
• Other information reasonably necessary for compliance purposes.

7. Identity Verification

Where KYC verification is required, Meeky Cart may use appropriate verification procedures and third-party identity verification providers. Verification may involve:

• Government-issued identity documents and Passport verification;
• National identity documents and Driver's licence verification;
• Proof of address and Electronic identity verification;
• Database checks and Fraud-prevention databases;
• Document authenticity checks;
• Selfie or biometric verification where legally permitted;
• Confirmation of telephone or email ownership; and
• Other lawful verification methods. Specific verification methods may vary by country and service.

8. Accuracy of Customer Information

Customers are responsible for providing accurate, complete, and current information. Customers must not:

• Provide false information or use another person's identity;
• Use forged documents or modify identity documents;
• Conceal material information or create accounts using fictitious identities;
• Misrepresent their residence or provide false business information; or
• Attempt to circumvent verification requirements.

Providing inaccurate information may result in account restrictions, cancellation of transactions, suspension, termination, or referral to relevant authorities where appropriate.

9. Verification of Businesses

Meeky Cart may require additional verification from businesses, companies, organizations, merchants, affiliates, resellers, or other commercial users. Information may include: registered business name, registration number, registered and trading addresses, business website, nature of business, directors, officers, owners, beneficial owners, authorized representatives, tax information, source of funds, expected transaction activity, and relevant licences or regulatory registrations.

10. Beneficial Ownership

Where Meeky Cart provides services to a legal entity or business customer, we may need to identify the individuals who ultimately own or control that entity. This includes identifying direct owners, indirect owners, controlling persons, directors, authorized representatives, and ultimate beneficial owners.

11. Enhanced Due Diligence (EDD)

Meeky Cart may apply Enhanced Due Diligence (“EDD”) where a customer, transaction, account, business relationship, or service presents elevated risk. EDD may include additional identity verification, address verification, source-of-funds verification, source-of-wealth information, corporate documentation, beneficial ownership verification, transaction-history review, payment verification, sanctions screening, adverse-media screening, and manual compliance reviews. Enhanced due diligence may be applied without prior notice where permitted by law.

12. Source of Funds & 13. Source of Wealth

For certain transactions or services, Meeky Cart may request information concerning the source of funds or source of wealth. This is particularly relevant where transaction values are unusually high, transaction patterns are unusual, multiple payment methods are used, third-party payment instruments are involved, refund activity is abnormal, gift cards/prepaid products are purchased in significant quantities, or transactions appear structured to avoid controls.

Lawful evidence may include documentation concerning employment, business ownership, investments, inheritance, sale of assets, business income, or other legitimate sources of wealth.

14. Anti-Money Laundering & 15. Terrorist Financing

Money laundering generally involves disguising the origin, ownership, or destination of proceeds derived from criminal activity. Meeky Cart strictly prohibits the use of its Platform or services for money laundering, terrorist financing, or activities designed to facilitate financial crime.

Customers must not use Meeky Cart to:

• Conceal criminal proceeds or transfer illicit funds;
• Disguise the source of funds or create fictitious transactions;
• Conduct transactions on behalf of unknown third parties without legitimate reason;
• Abuse refunds, vouchers, or gift cards;
• Launder funds through repeated purchases and refunds; or
• Use fraudulent payment instruments.

Where transactions or accounts appear connected to terrorist financing or prohibited activity, Meeky Cart may block transactions, suspend accounts, restrict services, conduct additional verification, report activity to authorities where legally required, and cooperate fully with law enforcement.

16. Fraud Prevention & 17. Payment Instrument Ownership

Meeky Cart maintains automated and manual controls to identify and prevent fraudulent activity (such as stolen cards, account takeover, fake identities, suspicious IP/device activity, abnormal velocity, and chargeback abuse).

Customers must only use payment methods that they are legally authorized to use. Meeky Cart may decline third-party payment methods or require proof of authorization where a payment method is registered in another person's name or triggers a fraud alert.

18. Gift Cards & Reloadable Visa Cards

Gift cards, prepaid products, and reloadable Visa cards may present additional financial-crime and fraud risks. Meeky Cart may apply additional controls including identity verification, purchase limits, reload limits, account restrictions, payment verification, velocity monitoring, and compliance reviews.

19. Meeky Cart-Only Card Usage

Where a reloadable or prepaid card product is designed for use exclusively within the Meeky Cart ecosystem, cards must not be used for unauthorized transfers, money laundering, cash-equivalent transactions where prohibited, circumvention of Platform controls, or fraudulent purchases.

20. Voucher Systems

Meeky Cart vouchers are subject to transaction limits and fraud-prevention controls. The Company investigates large-scale voucher purchases, voucher manipulation, unauthorized resale, and suspicious refund activity. Voucher balances may be restricted where necessary to protect against fraud.

21. Affiliate Program Compliance

Affiliates must not generate fraudulent transactions, use stolen payment methods, self-refer improperly, create fake accounts, manipulate commissions, use bots, or generate artificial traffic. Commissions may be withheld while suspicious activity is investigated.

22. Global Sourcing, 23. eSIM & 24. Phone Unlocking Services

Global Sourcing (22): Monitored across customer, supplier, logistics, and payment processor relationships to identify supplier fraud, payment abuse, and sanctions concerns.

eSIM Services (23): Subject to telecommunications, geographic, and fraud-prevention rules. Purchases may be restricted if destinations are unsupported or transactions appear manipulated.

Phone Unlocking (24): Requires verification of device ownership, IMEI, carrier, and payment authorization. Unlocking requests will be refused if there are reasonable grounds to believe the device or IMEI is lost, stolen, blocklisted, or fraudulent.

25. Sanctions Screening & 26. Politically Exposed Persons (PEPs)

Meeky Cart screens customers, transactions, and businesses against applicable sanctions and restricted-party lists maintained by South African authorities, United Nations bodies, UK authorities, US authorities (OFAC), European authorities, and other competent bodies.

Meeky Cart may identify whether a customer or beneficial owner is a Politically Exposed Person (“PEP”). PEP status does not automatically prohibit use of the Platform, but additional due diligence may be applied based on risk.

27. High-Risk Jurisdictions

Meeky Cart may restrict or apply enhanced controls to transactions involving jurisdictions that present elevated money laundering, terrorist financing, fraud, sanctions, regulatory, corruption, or payment processing risks.

28. Transaction Monitoring & 29. Suspicious Activity

Meeky Cart monitors transaction amounts, frequency, payment methods, geographic locations, device information, refund patterns, and login history. A transaction may be flagged for manual review if it appears inconsistent with expected activity.

30. Restrictions, 31. Suspension & 32. Account Termination

Meeky Cart may impose daily limits, purchase limits, reload limits, or payment method restrictions. Accounts may be temporarily suspended or permanently terminated where identity cannot be verified, fraud is confirmed, money laundering is suspected, sanctions apply, or required compliance documentation is refused.

33. Transaction Rejection & 34. Confidentiality of Reviews

Meeky Cart may reject, delay, cancel, or reverse transactions for fraud prevention, AML compliance, payment security, or legal obligations.

35. Regulatory Reporting

Where required by applicable law, Meeky Cart reports relevant information or suspicious transactions to competent financial intelligence and law enforcement authorities without prior notice to the customer.

36. Record Keeping & 37. Data Protection

Records relating to customer identity, transactions, payments, verification checks, communications, and risk assessments are retained for periods required by applicable law or legitimate compliance purposes. Personal information is processed in accordance with the Meeky Cart Privacy Policy and applicable data protection legislation (POPIA, GDPR, UK GDPR).

38. Third-Party Compliance Providers & 39. Customer Cooperation

Meeky Cart uses specialized third-party verification, sanctions screening, and fraud prevention providers. Customers are expected to cooperate with reasonable compliance requests within the requested timeframe.

40. Prohibited Use, 41. Pass-Through Transactions & 42. Multiple Accounts

Users must not use Meeky Cart as an informal money-transfer service, pass-through account, or for counterfeit transactions, tax evasion, or proceeds of crime. Creating multiple accounts to bypass KYC limits, promotional caps, or fraud controls is strictly prohibited.

43. Account Takeover, 44. Chargeback Abuse & 45. Refund Monitoring

Security controls (MFA, device monitoring, login tracking) protect against account takeover. Customers must not abuse payment chargebacks or engage in serial refund exploitation.

46. Internal Controls, 47. Partner Conduct & 48. Whistleblowing

Meeky Cart implements staff compliance training, fraud detection audits, and access controls. Employees and partners must not facilitate financial crime. Suspected misconduct or compliance concerns can be reported confidentially to info@meekycart.com.

49. No Guarantee, 50. Policy Updates & 51. No Circumvention

While rigorous controls are maintained, no security framework can guarantee complete prevention of financial crime. Customers must safeguard their credentials. Attempts to bypass compliance checks will result in immediate service termination.

52. Cooperation With Authorities, 53. International Compliance & 54. Policy Hierarchy

Meeky Cart cooperates with law enforcement, courts, financial intelligence centres, banks, and payment card schemes. This Policy operates alongside the general Terms & Conditions, Privacy Policy, Gift Card Terms, Voucher Terms, eSIM Terms, and Phone Unlocking Terms.

55. Compliance Decision-Making & 56. Fair Application

Meeky Cart applies risk-based compliance procedures objectively and without unlawful discrimination. The application of KYC or AML checks does not by itself imply that a customer has engaged in wrongdoing.

57. Contact Information & 58. Policy Version