Payline Financial Inc.recognizes that The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“Act”) imposes important new obligations on all financial firms for the detection, deterrance and reporting of money laundering activities. Under the Act, money laundering is defined as any financial transaction using income derived from criminal activity including, but not limited to, drug trafficking, fraud, illegal gambling and terrorism. Payline Financial has established the following policies to ensure thorough compliance with all laws and regulations regarding money laundering.

Prior to the opening of any new account, Payline Financial shall document the identity and nature of business of each prospective customer. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list shall not be permitted.

On an on-going basis, Payline Financial shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of:

money flows into and out of accounts,

the origin and destination of wire transfers,

non-economic transactions, and

other activity outside the normal course of business.

Every officer, employee, and associated person ("AP") of Payline Financial shall be responsible for assisting in the firm's efforts to undercover and report any activity that might constitute, indicate or raise suspicions of money laundering. To this end, Payline Financial shall provide continuing education and training of all such persons.

Should any officer, employee or AP of Payline Financial have any knowledge, suspicions or information regarding potential money laundering activities, that individual shall immediately notify Payline Financial's Compliance Department. Payline Financial's Compliance Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of Payline Financial.

Payline Financial shall comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, Payline Financial may supply information about former, current or prospective customers to such bodies.