COMPLIANCE CENTER

July 27, 2026

Entity ID: 20261852398

MSB Registration No.: 31000335734442 (Colorado, United States)

Our Commitment to Compliance

Eclipse Pay is a private on/off-ramp platform serving High-Net-Worth Individuals. We bridge the gap between traditional private banking and the digital asset economy, offering large-block stablecoin (USDC/USDT) to USD conversions and vice versa with same-day settlement, segregated custody, and white-glove service.

Compliance is the foundation of our business. As a fully regulated U.S. Money Services Business, we operate with absolute transparency to regulators while maintaining absolute privacy for our Clients. Our compliance program is designed to protect our Clients, our partners, and the integrity of the U.S. financial system.

This Compliance Center provides transparency into our regulatory standing, our anti-money laundering (AML) program, and the safeguards we have implemented across our platform.

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Regulatory Standing

U.S. MSB Registration

Applicable Regulatory Frameworks

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Anti-Money Laundering (AML) Program

Eclipse Pay maintains a comprehensive, risk-based AML Program that meets the requirements of U.S. federal and state regulatory frameworks. Our program is overseen by a designated Compliance Officer (BSA/AML Officer) and is reviewed and updated on a regular basis.

Program Components

1. BSA/AML Compliance Officer

A designated BSA/AML Compliance Officer is responsible for overseeing the AML Program, ensuring regulatory compliance, filing SARs, and serving as the primary point of contact with FinCEN, the Colorado Division of Securities, and other regulators.

2. Written Policies and Procedures

We maintain documented policies and procedures covering all aspects of our operations, including:

3. Risk Assessment

We conduct and maintain an enterprise-wide risk assessment that evaluates:

Clients are assigned a risk rating (Low, Medium, High) based on these factors, which determines the level of due diligence applied.

4. Training Program

All employees, officers, and relevant contractors receive AML training upon onboarding and annually thereafter. Training covers:

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Know Your Customer (KYC)

Client Onboarding

Every Client undergoes a thorough onboarding process before being approved to use the Services. Given our HNWI client base, our KYC process includes enhanced verification beyond standard BSA requirements.

Identity Verification

HNWI Status Verification

Sanctions, PEP, and Adverse Media Screening (via SumSub)

Wallet Verification (via Chainalysis)

Risk Rating

Each Client is assigned a risk rating based on:

Ongoing Due Diligence

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Transaction Monitoring

Real-Time and Post-Transaction Monitoring

Eclipse Pay monitors all Transactions using a combination of automated rules, blockchain analytics, and risk-based manual review:

Automated Monitoring

Blockchain Analytics (via Chainalysis)

Manual Review

Monitoring for Stablecoin-Specific Risks

As a USDC/USDT on/off-ramp platform, we apply specialized monitoring for:

Currency Transaction Reports (CTRs)

Eclipse Pay files Currency Transaction Reports (CTRs) with FinCEN for Transactions exceeding USD $10,000, as required by the BSA.

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Sanctions Compliance

Screening Program (via SumSub and Chainalysis)

Eclipse Pay conducts sanctions screening at multiple stages:

Client Onboarding

Ongoing Screening

Sanctions List Sources

Jurisdictional Restrictions

We do not provide services to Clients or process Transactions involving:

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Suspicious Activity Reporting

Reporting Obligations

Eclipse Pay files Suspicious Activity Reports (SARs) with FinCEN where there are reasonable grounds to suspect a Transaction is related to money laundering, terrorist financing, or other illicit activity.

FinCEN SAR Filing

Fraud Detection

Our transaction monitoring system includes fraud detection capabilities:

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Elder Financial Abuse and Vulnerable Person Protection

Our Commitment

Eclipse Pay is committed to protecting elderly individuals and other Vulnerable Persons from financial exploitation. Given that our Clients are HNWIs, we are particularly attentive to signs of undue influence, coercion, or exploitation by family members, caregivers, financial advisors, or other parties in a position of trust.

We have implemented a dedicated Elder Financial Abuse and Vulnerable Person Protection Program as part of our broader compliance framework.

Regulatory Framework

Our Elder Financial Abuse protections are aligned with:

Red Flags and Indicators

Our transaction monitoring system, blockchain analytics, and staff are trained to identify the following red flags:

Transaction Pattern Red Flags

Authorized Representative Red Flags

Behavioral Red Flags

Blockchain-Specific Red Flags (via Chainalysis)

Detection and Monitoring Measures

1. Automated Transaction Monitoring — Custom rules and models designed to flag Transaction patterns consistent with elder financial exploitation, including velocity checks, redirect pattern detection, and behavioral deviation analysis

2. Blockchain Analytics (Chainalysis) — Wallet risk scoring to identify whether Stablecoin movements show patterns consistent with exploitation (e.g., rapid pass-through to known fraud-associated wallets, transaction graph links to exploitation networks)

3. Manual Review — Trained compliance analysts review flagged Transactions, with specific training on elder financial abuse indicators. Relationship Managers are also trained to escalate behavioral concerns

4. Enhanced Due Diligence — Clients whose Transaction patterns show elevated elder abuse risk indicators are subject to enhanced due diligence, including direct contact with the Client (not through their Representative) to verify authorization

5. Authorized Representative Enhanced Scrutiny — All Transactions initiated by Authorized Representatives are subject to enhanced verification, including:

- Verification of the power of attorney or authorization document

- Direct contact with the Client to confirm instructions (where feasible and appropriate)

- Monitoring of Representative-initiated Transaction patterns

- Enhanced Chainalysis screening of Representative-provided wallet addresses

6. Staff Training — All compliance, operations, and Relationship Manager staff receive dedicated training on:

- Recognizing red flags of Elder Financial Abuse

- Understanding the tactics used by perpetrators of financial exploitation

- Proper escalation and reporting procedures

- Maintaining confidentiality and avoiding tipping-off

- Sensitivity when interacting with elderly or vulnerable Clients

- Distinguishing between legitimate Authorized Representative activity and potential exploitation

Reporting and Response

When Eclipse Pay suspects Elder Financial Abuse or the exploitation of a Vulnerable Person:

Internal Escalation

Regulatory Reporting

Protective Actions

Tipping-Off Prohibition

Eclipse Pay is legally prohibited from notifying the Client or any third party that a report of suspected Elder Financial Abuse has been or is being filed. All reports are made on a confidential basis.

Client Responsibilities

Clients of Eclipse Pay are expected to:

Recordkeeping for Elder Financial Abuse Cases

| Record Type | Minimum Retention | Regulatory Basis |

|---|---|---|

| Elder Financial Abuse investigation records | 5 years | BSA / FinCEN |

| SARs related to elder exploitation | 5 years after filing | BSA / FinCEN |

| Adult Protective Services reports | Per applicable state law | State elder abuse laws |

| Training records (elder abuse module) | 5 years | BSA / FinCEN |

  • Records are maintained in a manner that protects the privacy of vulnerable persons.

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    Recordkeeping

    Eclipse Pay maintains comprehensive records in compliance with U.S. regulatory requirements:

    | Record Type | Minimum Retention | Regulatory Basis |

    |---|---|---|

    | Client KYC records | 5 years after client relationship ends | BSA / FinCEN |

    | Transaction records | 5 years after transaction date | BSA / FinCEN |

    | SARs and related records | 5 years after filing | BSA / FinCEN |

    | CTRs | 5 years after filing | BSA / FinCEN |

    | Compliance training records (including elder abuse training) | 5 years | BSA / FinCEN |

    | Elder Financial Abuse investigation records | 5 years | BSA / FinCEN |

    | Risk assessments | 5 years (or latest 2 versions) | BSA / FinCEN |

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    Client Due Diligence Tiers

    Standard Due Diligence (SDD)

    Applied to Low-risk Clients:

    Enhanced Due Diligence (EDD)

    Applied to Medium and High-risk Clients, PEPs, and Clients with complex wealth structures:

    Simplified Due Diligence

    Not applied. Eclipse Pay applies at least SDD to all Clients, reflecting the high-value nature of our Transactions and our commitment to compliance.

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    Compliance Technology

    Eclipse Pay leverages industry-leading compliance technology to support our AML program, transaction monitoring, and client verification:

    SumSub

    Chainalysis

    Both tools are integrated into our compliance workflows and support our obligations under the BSA, FinCEN regulations, OFAC sanctions, and Elder Financial Abuse reporting requirements.

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    Custody and Security

    Segregated Custody

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    Whistleblower and Reporting Mechanism

    Eclipse Pay maintains an internal reporting mechanism for employees and contractors to report suspected compliance violations, fraud, Elder Financial Abuse, or unethical behavior. Reports can be made confidentially and, where permitted by law, anonymously. Retaliation against any individual who makes a good-faith report is strictly prohibited.

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    Audit and Independent Review

    Our AML Program, including the Elder Financial Abuse and Vulnerable Person Protection Program, is subject to:

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    Acceptable Use Policy Summary

    Permitted Use

    Prohibited Activities

    Restricted Activities (Require Pre-Approval)

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    Compliance Contact

    For compliance-related inquiries, regulatory requests, or to report a compliance concern including suspected Elder Financial Abuse:

    Eclipse Pay Inc.

    Attention: BSA/AML Compliance Officer

    Colorado, United States

    Entity ID: 20261852398

    MSB Registration No.: 31000335734442

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    This Compliance Center content is provided as a draft for review by legal and compliance counsel. It does not constitute legal advice. Please have qualified counsel review and customize this content before publication.