Transaction Monitoring and Compliance (KYT)

HoyaPay is committed to maintaining high standards of compliance and risk management within the digital asset ecosystem. To ensure transparency and security throughout the transaction lifecycle, we have established a comprehensive Know Your Transaction (KYT) framework designed to identify, monitor, and prevent potentially high-risk or suspicious transaction activities.

Prohibited Activities

HoyaPay strictly prohibits users from engaging in any form of illegal activity through the platform, including but not limited to money laundering, terrorist financing, or any other unlawful commercial activities.

All user transactions are subject to real-time and ongoing KYT monitoring. If any transaction is identified as potentially illegal or abnormal, HoyaPay will take appropriate measures in accordance with applicable laws and regulations, including but not limited to suspending or freezing accounts, rejecting fund movements, and, where required, reporting suspicious activities to relevant regulatory or law enforcement authorities.

High-Risk Activities to Avoid

HoyaPay strongly advises users to avoid the following activities in order to minimize the risk of transaction restrictions or account limitations:

• Violations of Economic Sanctions: Engaging in transactions that may violate economic sanctions imposed by governments or international organizations, including but not limited to those enforced by the U.S. Department of the Treasury, the United Nations Security Council, or other relevant authorities.

• Transactions Related to Illegal Activities: Including funds associated with fraud, stolen assets, ransomware, or other criminal activities.

• Unusual or Non-Commercially Reasonable Transaction Patterns: Such as immediately withdrawing funds after deposit without a legitimate or reasonable business justification.