Larimar Pay (“the Company”), a trading name of DS Fleming Investments Ltd, operates as a provider of front-end digital services enabling UK-based users to initiate cross-border payments through the infrastructure, compliance framework, and regulatory permissions of RemitJunction Limited, the FCA-regulated entity responsible for conducting regulated activities.

This policy outlines Larimar Pay’s internal approach to AML/CTF risk mitigation, supporting RemitJunction’s regulatory obligations and maintaining high standards of integrity, customer safety, and operational transparency.

● Larimar Pay is not authorised by the FCA to provide regulated money transfer services.

● All regulated activities (including KYC, transaction monitoring, screening, and reporting) are performed by RemitJunction Limited, the principal regulated entity.

● Larimar Pay acts as:

○ A Front-End Distributor/Introducer,

○ Responsible for marketing, customer onboarding facilitation through approved channels,

○ And end-user education/support.

Larimar Pay does not:

● perform KYC verification

● ● hold customer funds

● process regulated financial data

● approve transactions

perform sanctions screening

● determine AML/CTF risk ratings

These functions remain the responsibility of RemitJunction.

Even though Larimar Pay is not the regulated entity, it is committed to:

1. Supporting RemitJunction’s AML/CTF framework.

2. Identifying and escalating suspicious behaviour.

3. Ensuring accurate and compliant customer communications.

4. Preventing misuse of the platform for illicit purposes.

5. Maintaining internal controls and staff awareness.

Larimar Pay follows a risk-based approach aligned with RemitJunction’s policies:

● Higher-risk behaviours are escalated immediately.

● Staff training ensures awareness of AML/CTF red flags.

● All suspicious patterns detected at the user-interface level are logged and forwarded to RemitJunction’s compliance team.

Larimar Pay does not collect identity documents or verify customer identity.

All CDD is performed exclusively by RemitJunction, including:

● KYC checks

● ID verification

● Address verification

● Sanctions and PEP screening

● Enhanced Due Diligence (EDD)

Customers who fail or bypass CDD are blocked from using Larimar Pay.

Larimar Pay monitors front-end user behaviour and escalates concerns to RemitJunction.

Examples include:

● unusual login patterns

● multiple accounts tied to same device

● customer attempting to avoid verification

● repeated failed ID submissions

● behaviour inconsistent with typical remittance use

Larimar Pay does not file SARs — this is the responsibility of RemitJunction’s MLRO.

All Larimar Pay personnel receive:

● AML awareness training

● CTF red-flag recognition

● Escalation pathways

● Data protection training

Training occurs at onboarding and annually.

Larimar Pay maintains:

● customer communication logs

● support tickets

● internal flags

● escalation logs

Identifiable KYC documents are not storedby Larimar Pay.

All data-sharing follows:

● RemitJunction’s Data Controller role

● GDPR principles

● ICO guidelines

● secure encrypted channels

Larimar Pay acts as a Data Processoronly for non-regulated data categories (contact details, support interactions, marketing preferences).

This AML/CTF policy is reviewed annuallyor after regulatory/operational changes.

Approved By:

Name: Gabriel De Oleo Santana
Role: Managing Director / Founder – Larimar Pay
Date: 01/12/2025