AML / KYC Policy

Bridge Ltd. ("Bridge") and its licensed banking sponsor maintain a risk-based Anti-Money-Laundering (AML), Counter-Terrorist Financing (CTF), and Know-Your-Customer/Know-Your-Business (KYC/KYB) program designed to prevent the Service from being used to facilitate money laundering, terrorist financing, sanctions evasion, or other financial crime. This is a template and should be reviewed by qualified legal and compliance counsel before use in production, and adapted to reflect the specific regulatory regime(s) applicable to your operations.

1. Purpose & Scope

This policy applies to every corporate entity, authorized user, and cardholder onboarded through the Bridge platform, and governs the verification, monitoring, and reporting obligations we and our Sponsor Bank apply before and after a corporate card program is approved.

2. Regulatory Framework

Our program is designed to align with applicable anti-money laundering laws and regulations, card network rules (Visa and Mastercard), and guidance issued by relevant financial regulators and standard-setting bodies, including risk-based customer due diligence principles consistent with FATF recommendations.

3. Customer Due Diligence (CDD) & KYB

Before a corporate account is approved, we require:

• Certificate of incorporation and business registration number.
• Proof of registered business address (e.g. utility bill, bank statement, or official registry extract).
• Government-issued identification for directors and authorized signatories.
• Beneficial ownership disclosure for individuals holding 25% or more of the entity, directly or indirectly.
• Information about the nature of the business, expected transaction volumes, and use case for corporate cards.

4. Enhanced Due Diligence (EDD)

Additional verification and documentation may be required for corporates presenting higher risk factors, such as operating in higher-risk jurisdictions, complex ownership structures, unusually high transaction volumes, or association with politically exposed persons (PEPs). EDD may include source-of-funds documentation and senior management sign-off before approval.

5. Beneficial Ownership

Corporates must accurately disclose all individuals who own or control 25% or more of the entity, or who otherwise exercise significant control. Beneficial ownership information is verified against identification documents and re-confirmed periodically or upon material corporate changes.

6. Ongoing Monitoring

Card transactions are monitored on an ongoing basis for patterns consistent with money laundering, fraud, structuring, or sanctions violations. Automated and manual reviews may trigger requests for additional information, temporary holds, or card freezes pending investigation.

7. Sanctions & PEP Screening

All corporates, authorized signatories, and beneficial owners are screened against applicable sanctions lists, watchlists, and politically exposed persons databases before approval and on an ongoing basis thereafter. A confirmed sanctions match will result in immediate rejection or suspension of the account, as required by law.

8. Recordkeeping

KYC/KYB documentation, transaction records, and monitoring outcomes are retained for the period required by applicable law — typically no less than five years following the end of the business relationship — and are made available to regulators and law enforcement upon lawful request.

9. Suspicious Activity Reporting

Where we identify activity reasonably suspected to be linked to money laundering, terrorist financing, or other financial crime, we and/or our Sponsor Bank will file suspicious activity reports with the relevant authorities as required by law, and may not be able to notify the affected corporate of such a report.

10. Employee Training

Personnel involved in onboarding, compliance, and customer support receive periodic training on AML/KYC obligations, red flags, and escalation procedures.

11. Cooperation with Authorities

Bridge and its Sponsor Bank cooperate fully with regulators, law enforcement, and other competent authorities in connection with AML/KYC investigations and requests.

12. Contact

Questions about this policy, or requests to update KYC/KYB information, can be directed to support@bridgeltd.net.