Slide 1: Enterprise Risk Management Update
Enterprise Risk Management Update Wayne Gonzales APRIL 17, 2025
Slide 2: ERM Team
ERM Team Joseph Saahene Garrett Cox Brittany Kearn VP - General Counsel Sr. Director Risk Ops Sr. Risk Analyst Keyontae Brown Peyge Wolfe Vanessa Martinez Risk Analyst Risk Analyst Risk Analyst
Slide 3: Pillars of AML Program
Effective Controls ‘The company should follow documented policies and procedures that guide its actions Pillars of AML Program Designation of AML Officer A senior compliance officer should be designated to oversee the general application of AML regulations throughout the institution. Employee Traini
Slide 4: Top Risks to Company
Top Risks to Company 1. Regulatory Risk 2. Sending Money to the wrong place 3. Hacking / Data Loss 4. Chargeback& Fraud 5. Lack of Execution / Making Poor Decisions
Slide 5: FinCEN CDD Rule
FinCEN CDD Rule OBTAIN & VERIFY Requires a covered institution (USIO) to obtain and verify identities of individuals owning 25% or more of an entity Vitae DUE OWNERSHIP DILIGENCE & TRUSTEE If Entity A owns 25% or more, of e BENEFICIAL OWNERSHIP If Trust owns 25% or more. Entity B, covered institutio
Slide 6: ACH Fraud Transaction Detection
ACH Fraud Transaction Detection
Slide 7: 2024 Pre-Notes
2024 Pre-Notes 12.76MM Pre-Notes Debit Trans TOTAL DEBIT ENTRIES TOTAL PRE-NOTES 3,658,380 3638303 1,667,234 3203284 3246704 2675752 FLOATME PRE-NOTES 848531 885401 1070022 854426 EXPLORE PRE-NOTES 438,337 Q1 Q2 Q3 Q4 FLOATME = 46% EXPLORE = 12%
Slide 8: 2025 Pre-Notes
2025 Pre-Notes 4,639,506 Pre-Notes Debit Trans TOTAL DEBIT ENTRIES TOTAL PRE-NOTES 1,461,173 3954353 472,289 FLOATME PRE-NOTES 1261412 685153 EXPLORE PRE-NOTES 307,655 Q1 Q2 FLOATME = 32% EXPLORE = 22%
Slide 9: DocuSign Envelopes Sent
DocuSign Envelopes Sent Jan Feb Mar Apr 10 8 6 4 2 0 Issuing Sales Payments Sales Output Sales INCLUDES ALL ENVELOPES SENT BY PEOPLE IN GROUP
Slide 10: Agreement Redlines
Agreement Redlines Output Sales 4 Issuing Sales 7 Payments Sales 15
Slide 11: 2025 Enrollment Stats
2025 Enrollment Stats Went To Risk 215 New Accounts 420
Slide 12: 2025 Enrollment Stats
2025 Enrollment Stats 5 4 Avg Days in Risk Avg Days to KYC AVG TIME OF APPROVAL = <5 MINS
Slide 13: Enrollments
Enrollments Data Integrity Issues Result of Data Integrity Issues • Nickname instead of Legal Name • Inadequate Screening • Prefix and suffix (Dr, PhD, Sir) • Undermines risk modeling and assessment • SSN transposed • Regulatory risk • DOB transposed • Delayed onboarding • Company Legal Name incorre
Slide 14: Unified Enrollment ~$130k
Unified Enrollment We currently have at least two (2) different methods of onboarding ~$130k • Jumio: ~$35k • Socure: ~$80k Annual KYC Expense • LN/TINCheck: ~$15k Kompliant’s KYC solution is a white-label plug and play solution. They maintain all third-party vendor agreements. Reduces KYC/KYB/IDV e
Slide 15: Compliance Liability
Compliance Liability Compliance Officers (COs) in the Fintech industry are increasingly being held personally liable for compliance failures. This is driven by factors such as regulatory scrutiny, evolving technologies, and a growing emphasis on individual accountability. COs can face significant le
Slide 16: Confirmed Fraudulent Addresses
e e 8 ° ee? e eo © @g Se? ge ot é e ¢° Los Angeles 4 5 ex is e@ * @ va @ iDaliias: @ e e ew "Oe \ © ce Se Sn é . 0% . ake roo) ‘GD eo ee eo. oe e 4 e Confirmed Fraudulent Addresses © usio
Slide 17: 2024 Risk Overview
2024 Risk Overview $5 BILLION + Processed across all LOBs -$693,163.38 Total Loss (Issuing + Acquiring) $3.11 MILLION Fraud / Loss Prevented $178,617.66 Recovered © usio
Slide 18: 2025 Risk Overview
2025 Risk Overview OUR LOSS RATE IS CURRENTLY 0.007%