AML / CFT POLICY

1. Purpose and Scope

Outlink is committed to conducting business in compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CFT) laws and regulations. This policy sets out the measures we have adopted to prevent Outlink’s platform from being used for money laundering, terrorist financing, or other illicit financial activities.

This policy applies to all employees, contractors, service providers, advertisers, publishers, and partners using the Outlink platform.

2. Policy Statement

Outlink has a zero-tolerance policy towards money laundering and the financing of terrorism. We will take all reasonable and proportionate steps to:

• Prevent individuals or entities engaged in illicit activities from accessing our services.

• Identify and mitigate risks associated with suspicious activities.

• Fully comply with sanctions regimes, AML/CFT legislation, and reporting obligations in the jurisdictions in which we operate.

3. Core Principles

Know Your Customer (KYC): Outlink verifies the identity of publishers before onboarding and reserves the right to request additional documentation.

• Risk-Based Approach: Enhanced due diligence is applied to high-risk accounts, transactions, and jurisdictions.

• Continuous Monitoring: Automated and manual reviews are performed to detect unusual or suspicious activity.

• Regulatory Compliance: Outlink complies with relevant laws, sanctions, and guidance from financial regulators and law enforcement agencies.

4. Risk Controls and Procedures

4.1 Sanctions & Jurisdiction Screening

Outlink blocks access from sanctioned countries and jurisdictions using IP address detection and billing information.

Outlink may screen users against global sanctions lists (OFAC, UN, EU, UK, etc.).

4.2 Account Monitoring

All advertiser accounts undergo regular automated checks to ensure activity is genuine, consistent with their stated business, and compliant with our Terms of Service.

Transactions are monitored for red flags, such as:

• Unusually large or rapid transactions

• Mismatched billing details

• Multiple accounts linked to the same payment method

• Use of anonymizing technologies (e.g., VPNs, proxies) to conceal jurisdiction

4.3 Human Review

Transactions above USD 10,000 or otherwise flagged as suspicious are escalated to compliance officers for manual review.

Outlink may request supporting documentation (e.g., proof of services, business justification).

Outlink reserves the right to suspend or terminate accounts pending further investigation.

4.4 Record Keeping

Outlink retains records of customer identification, verification, and transaction history for a maximum of 10 years, in line with regulatory requirements.

4.5 Reporting

Outlink will promptly report suspicious transactions to the relevant financial intelligence units (FIUs) or competent authorities as required by law.

Employees are trained to escalate concerns internally through designated compliance channels.

5. Policy Review

This policy will be reviewed at least annually, or sooner if required by regulatory changes, business expansion, or changes in risk profile. Updates will be communicated to all relevant stakeholders.

6. Enforcement

Non-compliance with this policy may result in disciplinary action, account suspension, termination of services, and/or reporting to regulatory authorities.