1. NATURE OF SERVICES AND REGULATORY STATUS OF MONEYWAYS

MoneyWays LLC (“MoneyWays”) is a Florida-licensed Money Services Business (MSB) operating under the authority of the Florida Office of Financial Regulation (OFR) pursuant to Chapter 560, Florida Statutes. MoneyWays is also registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business under 31 CFR § 1022.380 and maintains a compliance program in accordance with the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq.

MoneyWays provides payment facilitation services through its EPAY module. In this capacity, MoneyWays:

• • Is not the merchant of record for any transaction processed through its platform;

• • Does not sell, supply, or otherwise provide goods or services to end customers;

• • Does not assume obligations related to the delivery, quality, legality, or fulfillment of merchant transactions;

• • Does not operate as a stored-value provider or digital wallet for discretionary refund purposes;

• • Does not hold funds for the benefit of customers beyond the scope of regulated money transmission activities as defined under Fla. Stat. § 560.103.

All transactions processed through MoneyWays represent direct commercial transactions between the merchant and the end customer (“Direct Service Invoicing” model). The merchant is the sole party responsible for the commercial relationship and any obligations arising therefrom.

2. MERCHANT RESPONSIBILITY FOR REFUNDS AND RETURNS

Each merchant accessing MoneyWays’ EPAY platform is solely and exclusively responsible for:

• • Establishing, maintaining, and prominently disclosing its own refund and return policy prior to the completion of any transaction;

• • Processing all refunds directly to the original payment method used by the customer, in compliance with applicable card network rules (Visa Core Rules and Mastercard Rules);

• • Honoring all applicable federal and Florida consumer protection statutes and regulations;

• • Resolving all disputes related to goods or services provided, including any claims under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Fla. Stat. §§ 501.201 et seq.;

• • Maintaining transaction documentation sufficient to defend chargebacks and regulatory inquiries.

Merchant refund policies must, at minimum, include:

• • Timeframes for requesting refunds (including non-refundable designations where applicable);

• • Eligibility conditions and any exclusions;

• • Cancellation terms;

• • Customer support contact information.

3. REFUND PROCESSING THROUGH EPAY

Where applicable, refunds may be processed through the MoneyWays EPAY system, subject to the following conditions:

• • Refunds may only be issued for valid, completed transactions originally processed through EPAY;

• • Refunds must be initiated by the merchant and are subject to available merchant balance and reserve levels;

• • Refunds will be returned to the original payment method to the extent required by applicable card network rules;

• • Processing timelines are dependent on the issuing bank, card network, and payment processor; MoneyWays does not guarantee specific refund timelines.

MoneyWays reserves the right to delay or suspend refund processing if: (i) the underlying transaction is subject to a hold or investigation; (ii) OFAC screening identifies a potential sanctions match (see Section 9); or (iii) the refund triggers a Suspicious Activity Report (SAR) obligation under 31 CFR § 1022.320.

4. NO OBLIGATION OF MONEYWAYS TO ISSUE REFUNDS

MoneyWays has no obligation to:

• • Issue refunds on behalf of merchants to end customers;

• • Intervene in commercial disputes between merchants and their customers;

• • Guarantee the outcome of any refund request or chargeback dispute.

• • All refund-related claims by end customers must be addressed directly with the merchant. MoneyWays’ involvement in any refund transaction is limited to its role as a licensed money transmitter processing payment instructions at the direction of the merchant.

5. CHARGEBACKS AND DISPUTE HANDLING

A chargeback occurs when a cardholder disputes a transaction through their issuing bank, triggering a reversal mechanism under the applicable card network rules (Visa Core Rules, Mastercard Rules and Regulations). Chargebacks represent a significant compliance and financial risk area for MoneyWays as a licensed MSB.

5.1 Merchant Obligations

• • The merchant bears full and exclusive responsibility for responding to chargeback disputes and providing required supporting documentation;

• • Merchants must maintain adequate records of: proof of service delivery or product fulfillment, signed authorizations or electronic consent, delivery confirmations, customer communications, and identity verification records where applicable;

• • Merchants must respond to disputes within the timeframes required by the applicable card network (generally 20–45 calendar days from notification);

• • Failure to respond timely will result in automatic chargeback debit from the merchant’s account or reserve.

5.2 MoneyWays’ Role in Dispute Handling

• • MoneyWays may assist in transmitting dispute documentation to the relevant processor or card network but does not assume liability for dispute outcomes;

• • Chargeback amounts, including any associated fees and assessments imposed by the card network or processor, will be debited from the merchant’s settlement balance or applied against any rolling reserve;

• • MoneyWays reserves the right to withhold settlement funds pending resolution of disputed transactions.

6. CHARGEBACK MONITORING AND THRESHOLDS

MoneyWays actively monitors merchant chargeback ratios on a monthly basis in alignment with Visa and Mastercard chargeback monitoring program thresholds. Elevated chargeback rates may trigger regulatory reporting obligations and enhanced due diligence requirements under MoneyWays’ BSA/AML compliance program.

Monitoring Level	Chargeback Ratio	Timeframe	MoneyWays Action
Standard Monitoring	< 0.65%	Monthly	Routine oversight
Early Warning	0.65% – 0.90%	Monthly	Corrective Action Plan required
Excessive	≥ 1.00%	Monthly	Reserves + settlement delay
High-Risk / Critical	≥ 3.00%	Monthly	Suspension or termination

Upon reaching Early Warning or Excessive thresholds, MoneyWays may, in its sole discretion and without prior notice:

• • Require submission of a written Corrective Action Plan within 15 business days;

• • Increase monitoring frequency to weekly or real-time;

• • Apply or increase rolling reserves (up to 15% of gross transaction volume for 180 days or such longer period as risk warrants);

• • Delay settlement cycles;

• • Suspend or terminate the merchant’s access to EPAY services.

7. FRAUD AND UNAUTHORIZED TRANSACTIONS

The merchant is solely responsible for:

• • Preventing fraudulent transactions from being processed through EPAY, including implementation of appropriate fraud detection tools and controls;

• • Verifying customer identity where applicable and maintaining documentation of verification procedures;

• • Ensuring all transactions are supported by valid, authorized payment credentials;

• • Implementing industry-standard security measures including PCI-DSS compliance where required.

Unauthorized or fraudulent transactions may result in chargebacks, financial liability for the merchant, additional monitoring, account restrictions, and/or termination of services. MoneyWays does not assume responsibility for fraud losses.

8. OFAC SANCTIONS COMPLIANCE — REFUNDS, REVERSALS AND CHARGEBACKS

MoneyWays maintains a full-scope OFAC sanctions compliance program as required under 31 CFR Part 501 and applicable executive orders. All transactions processed through EPAY, including refunds, reversals, and chargeback-related fund movements, are subject to OFAC screening requirements.

8.1 Screening Obligations

1. • All parties involved in a refund or chargeback — including the original payee, refund recipient, and any intermediary financial institution — are subject to screening against the OFAC Specially Designated Nationals and Blocked Persons List (SDN List) and all applicable sanctions programs;

1. • Screening is performed at the time of the original transaction and, where operationally required, at the time of refund initiation or chargeback processing.

8.2 Blocked and Rejected Transactions

• • If a refund, reversal, or chargeback-related transaction involves a sanctioned party, blocked jurisdiction, or prohibited transaction type, MoneyWays is required by law to block or reject the transaction;

• • Blocked funds will be placed in a segregated interest-bearing account as required under 31 CFR § 501.603;

• • MoneyWays will file an OFAC report within ten (10) business days of blocking or rejecting a transaction, as required under 31 CFR § 501.604;

• • Merchants whose refunds or chargeback-related transactions trigger OFAC blocks will be notified to the extent permitted by law and subject to immediate account review.

9. RESERVES, SET-OFF, AND WITHHOLDING RIGHTS

To mitigate financial, regulatory, and compliance risk, MoneyWays reserves the right, without prior notice, to:

• • Withhold funds from settlement;

• • Establish, increase, or extend rolling reserves;

• • Delay or suspend settlement cycles;

• • Set off amounts owed by the merchant against any funds held by MoneyWays.

These measures may be applied without limitation in cases including but not limited to:

• • Elevated chargeback ratios (as defined in Section 6);

• • Suspicious transaction patterns triggering BSA/AML review;

• • Pending OFAC screening or investigation (Section 8);

• • Regulatory inquiry, examination, or subpoena;

• • Merchant insolvency, cessation of business, or material breach of the MoneyWays User Agreement.

10. PROHIBITION OF REFUND ABUSE AND PROHIBITED CONDUCT

Merchants are strictly prohibited from:

• • Issuing refunds outside of authorized EPAY channels or to payment methods other than the original funding source;

• • Using refund transactions to manipulate reported transaction volumes, revenue figures, or chargeback ratios;

• • Engaging in “friendly fraud” — collusive chargeback schemes involving the merchant and the cardholder;

• • Structuring refund transactions to avoid reporting thresholds under the BSA (31 U.S.C. § 5324);

• • Initiating refunds in connection with OFAC-blocked or sanctioned transactions;

• • Processing refunds for transactions not originally processed through EPAY (“cash out” schemes).

Any of the foregoing conduct may result in immediate suspension or termination of services, debit of any outstanding obligations from merchant reserves, referral to FinCEN or OFAC, and/or referral to law enforcement authorities

11. COMPLIANCE WITH CARD NETWORK RULES

All merchants must maintain continuous compliance with the rules, regulations, and standards of the applicable card networks, including without limitation:

• • Visa Core Rules and Visa Product and Service Rules (as amended from time to time);

• • Mastercard Rules (as amended from time to time);

• • PCI-DSS standards for data security;

• • Card network requirements for refund processing, dispute resolution, and chargeback response.

Failure to comply with card network rules may result in financial penalties assessed against MoneyWays and passed through to the merchant, account suspension, termination of card acceptance privileges, and/or placement on industry monitoring lists (e.g., MATCH/TMF).

12. CURRENCY TRANSACTION REPORTING OBLIGATIONS

MoneyWays is required to file Currency Transaction Reports (CTRs) with FinCEN for cash transactions exceeding $10,000 in a single business day pursuant to 31 CFR § 1022.310. This reporting obligation applies regardless of whether the transaction involves a payment, refund, or chargeback-related cash movement.

Merchants must:

• • Provide accurate and complete identification information for CTR purposes upon request;

• • Refrain from structuring or splitting transactions to avoid CTR filing obligations;

• • Cooperate with MoneyWays’ CTR collection procedures as a condition of continued access to EPAY services.

13. LIMITATION OF LIABILITY

MoneyWays shall not be liable for:

• • Any merchant’s failure to deliver goods or services to end customers;

• • Outcomes of refund requests, disputes, or chargeback proceedings;

• • Chargebacks, fines, or penalties assessed by card networks as a result of merchant conduct;

• • Losses resulting from fraudulent transactions processed through EPAY;

• • Delays in refund or settlement processing caused by regulatory holds, OFAC screening, or BSA/AML review;

• • Consequences arising from a merchant’s failure to comply with applicable law or card network rules.

The merchant assumes full financial and operational responsibility for the foregoing. In no event shall MoneyWays’ aggregate liability exceed the fees paid by the merchant to MoneyWays in the thirty (30) days immediately preceding the event giving rise to the claim.

14. REGULATORY COMPLIANCE MATRIX

The following matrix summarizes the key regulatory frameworks applicable to MoneyWays’ refund, returns, and chargeback operations:

Regulatory Framework	Applicable Provision	Obligation for MoneyWays
Fla. Stat. § 560.1235	Transaction recordkeeping (MSB)	Retain all transaction records ≥ 5 years
Fla. Stat. § 560.309	Prohibited acts (MSB)	No facilitation of unlawful transactions; no structuring
31 CFR § 1022.210	AML Program (FinCEN / BSA)	Written AML program, independent testing, designated BSA Officer
31 CFR § 1022.320	Suspicious Activity Reports	File SAR within 30 days of detection; no tipping-off
31 CFR § 1022.310	Currency Transaction Reports	File CTR for cash txns > $10,000; no structuring
31 CFR § 1010.410	Travel Rule (Transmittals ≥ $3,000)	Collect & retain originator/beneficiary info
31 CFR Part 501 (OFAC)	Sanctions screening & blocking	Screen all parties; block / reject prohibited txns; report to OFAC within 10 days
Fla. Stat. § 560.1401	Authorized Delegates	Delegate agreements; oversight; compliance obligations flow-down

15. INTEGRATION WITH MONEYWAYS USER AGREEMENT AND OTHER POLICIES

This Policy must be read in conjunction with the following MoneyWays documents:

• • MoneyWays User Agreement;

• • MoneyWays BSA/AML Compliance Program (internal);

• • MoneyWays OFAC Compliance Program (internal);

• • MoneyWays Merchant Agreement;

In the event of any conflict between this Policy and the MoneyWays User Agreement, the User Agreement shall control. In the event of any conflict between this Policy and applicable federal or Florida law or regulation, the applicable law or regulation shall control.