AML, KYC & Sanctions Statement

Metric House LLC is committed to preventing its business and its payment channels from being used to launder money, finance terrorism, evade sanctions or commit fraud. We regard financial-crime prevention as a condition of operating, not an administrative formality.

This statement summarises the controls we apply. It is published so that clients, suppliers, banking partners and payment service providers can understand our approach before entering into a relationship with us.

As a company formed in the United States, we operate with regard to the federal anti-money-laundering and counter-terrorist-financing framework — including the Bank Secrecy Act as amended, the sanctions programs administered by the Office of Foreign Assets Control, and the beneficial-ownership reporting rules administered by FinCEN — and to the standards our banking and payment partners require of the merchants they serve. Where we sell into other markets, we also respect the consumer-protection and financial-crime rules that apply there.

Our controls are designed on a risk-based approach: the depth of due diligence we apply is proportionate to the risk presented by the customer, the product, the channel and the country involved.

• Overall responsibility for financial-crime compliance sits with the company's management, which approves this statement and reviews it at least annually.
• A named compliance contact is responsible for day-to-day application of the controls described here, for escalation, and for liaison with banking and payment partners.
• Compliance decisions — including decisions to decline or exit a relationship — are recorded with the reasoning behind them.
• Employees and contractors are required to follow this statement and to escalate concerns without fear of reprisal.

Before we enter into a business relationship with a client or a supplier, we carry out due diligence proportionate to the risk. Every client is onboarded this way — there is no engagement that skips it. Due diligence normally includes:

• identification of the legal entity, including its certificate of formation, incorporation or equivalent registry record;
• identification of directors, authorised signatories and ultimate beneficial owners;
• understanding the nature and purpose of the intended relationship;
• confirmation of the source of funds where the relationship involves material sums;
• sanctions, politically-exposed-person and adverse-media screening; and
• an assessment against the categories in our Acceptable Use Policy.

We also assess what the prospective client actually sells and how it makes money, because we will be marketing it. A client whose business falls within a prohibited category, whose product claims cannot be substantiated, or whose ownership we cannot establish is declined.

We apply enhanced due diligence, and senior approval is required, where:

• a counterparty is established in, or transacts materially with, a higher-risk jurisdiction;
• a counterparty, or a beneficial owner of it, is a politically exposed person;
• the ownership structure is unusually complex or opaque without commercial justification;
• screening returns a possible sanctions or adverse-media match; or
• the pattern of transactions is inconsistent with the stated business purpose.

We screen counterparties, and where appropriate order and delivery data, against the sanctions lists maintained by the United States Office of Foreign Assets Control, the United Nations, the European Union and the United Kingdom.

• We do not knowingly transact with a designated person or entity, or with a party owned or controlled by one.
• We do not ship to, or accept payment originating from, a comprehensively sanctioned territory.
• A confirmed match results in the transaction being stopped and escalated. A potential match is reviewed before the transaction proceeds.
• We do not facilitate the circumvention of any sanctions or export-control measure.

Transactions are monitored for indicators inconsistent with normal customer behaviour, including:

• fee payments inconsistent with the engagement's size or the client's profile;
• settlement from an entity or country unrelated to the contracting client;
• requests to overpay an invoice and refund the balance elsewhere;
• requests to invoice a party other than the client named in the scope of work; and
• payment or chargeback patterns suggesting abuse.

We also rely on the fraud-prevention tools operated by our payment service providers, including 3-D Secure authentication where available. Payments that cannot be satisfactorily verified are returned rather than applied to an engagement.

• We receive fee income only. The money we receive is payment for services we have performed for the client that engaged us. We do not collect, hold, route or process payments on behalf of any client, and we are not a merchant of record, payment facilitator, aggregator or reseller for any third party.
• Client customer revenue never reaches us. A client's own sales are collected by that client, through that client's payment provider, into that client's account.
• We accept payment through regulated card networks, bank transfer and other regulated payment methods. We do not accept anonymous payment instruments.
• We do not accept cash payments for our services.
• We do not accept payment in virtual assets or cryptocurrency.
• We accept payment only from the client named in the scope of work, and refunds are returned to the original payment method and payer only.

We retain due-diligence records, transaction records, screening results and the reasoning behind compliance decisions for at least five years after the end of the business relationship or the date of the transaction, whichever is later. Records are stored securely, with access limited to those who need it, and are made available to competent authorities and to our banking partners on lawful request.

Where we identify activity we know or suspect to be linked to money laundering, terrorist financing or another financial crime, we escalate it internally, report it to the competent authority where we are required to do so, and cooperate with any resulting investigation. We do not disclose to a customer that a report has been made where doing so would amount to tipping off.

Personnel involved in onboarding, order processing, payments and customer support receive guidance on this statement when they join and are briefed when it changes. The controls described here are reviewed at least annually, and sooner where our activities, our markets, or the applicable rules change materially.

We work openly with our banking partners, acquirers and payment service providers. On request we provide our formation documents and corporate registry record, ownership information, business and revenue-model description, policy set, client contracts and sample invoices so that they can meet their own regulatory obligations. Enquiries from financial institutions should be directed to info@metrichouse.net and are prioritised.