Anti-Money Laundering & Counter-Terrorism Financing Policy

1. Company Overview

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy applies to Optimark Media LTD (UK) and PD Cash LLC (USA), collectively referred to as "the Company."

The Company provides professional consulting services in digital marketing, cloud infrastructure, and business technology. We are a newly incorporated, low-risk, non-custodial service provider. We do not hold, transfer, or process funds on behalf of third parties. All payments received are solely for services rendered directly to our clients.

2. Risk Profile

The Company maintains a low-risk profile for money laundering and terrorist financing due to the following factors:

• We provide professional consulting services only; we do not offer financial services
• We do not hold client funds or act as an intermediary for payments
• All transactions are direct payments for services rendered
• We process payments exclusively through regulated third-party payment processors (Stripe, PayPal, Square)
• Our client base consists primarily of businesses and professionals in established markets

3. Client Verification Procedures

Prior to establishing a business relationship, we verify the legitimacy of our clients through the following measures:

• Collection of client name, email address, and contact information
• Verification of email address through confirmation
• For business clients: collection of company name and business details
• Review of payment method to ensure it originates from a legitimate, regulated source
• Rejection of clients who refuse to provide basic identification information

Enhanced verification may be conducted for high-value transactions or when risk indicators are present.

4. Transaction Monitoring

We monitor transactions for suspicious activity, including:

• Unusually large or frequent purchases inconsistent with the client's stated needs
• Requests to split transactions without legitimate business reason
• Payments from jurisdictions unrelated to the client's stated location
• Attempts to pay using multiple payment methods for a single transaction
• Clients who are evasive about their identity or business purpose

Any suspicious activity is escalated internally for review and, where required by law, reported to the appropriate authorities.

5. Sanctions Screening

We do not provide services to individuals, entities, or residents of countries subject to comprehensive sanctions. We screen against:

• UK HM Treasury Sanctions List
• US OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List

We do not provide services to clients located in or associated with sanctioned jurisdictions including, but not limited to: North Korea, Iran, Syria, Cuba, and the Crimea, Donetsk, and Luhansk regions.

6. Record Keeping

We maintain records of all business transactions in compliance with applicable laws:

• Client identification records: retained for 5 years after the business relationship ends
• Transaction records (invoices, receipts, payment confirmations): retained for 7 years
• Communication records related to services provided: retained for 5 years

All records are stored securely and made available to competent authorities upon lawful request.

7. Prohibited Activities

The Company will not:

• Accept cash payments or cryptocurrency
• Process payments on behalf of third parties
• Provide services to clients on sanctions lists
• Engage in transactions with no clear business purpose

8. Compliance Responsibility

Management is responsible for ensuring adherence to this policy. This policy is reviewed annually and updated as necessary to reflect changes in regulations or business operations.

9. Contact Information

For compliance inquiries:

Tech Provider: PD Cash LLC
30 N Gould St, STE R, Sheridan, WY 82801, USA
Phone: +1 210 201 6000

Service Provider: Optimark Media LTD
20 Wenlock Road, London, N1 7GU, England
Phone: +44 7474 711663

Email: support@optimarkmedia.com