Compliance & AML/CTF Policy

This Compliance & AML/CTF Policy (Policy) outlines the compliance, risk-management and monitoring measures adopted by A2 SQUARE PTY LTD (ACN 683 920 390) trading as Tap Ease.

This Policy forms part of, and is incorporated into, the Tap Ease Website Terms & Conditions. Capitalised terms have the meanings given in those Terms.

1. Purpose and Regulatory Context

1.1 Tap Ease operates in a regulated financial and payments environment and is required to maintain appropriate systems and controls to manage operational, fraud and compliance risk.

1.2 This Policy explains how Tap Ease monitors usage, cooperates with financial institutions and authorities, and manages risk associated with the use of payment terminals and related services.

1.3 Nothing in this Policy constitutes an admission that Tap Ease provides a "designated service" for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

2. Risk-Based Monitoring

2.1 Tap Ease adopts a risk-based approach to monitoring the use of its Services.

2.2 Monitoring activities may include: (a) review of transaction patterns and anomalies; (b) assessment of refund and chargeback activity; (c) verification of user identity and eligibility information; (d) review of usage behaviour for compliance and risk indicators.

2.3 Monitoring is conducted for legitimate business, security and compliance purposes.

3. Information Requests and Verification

3.1 Tap Ease may request information, explanations or documentation from users where activity raises risk, compliance or security concerns.

3.2 Failure to provide requested information may result in suspension, restriction or termination of access.

4. Cooperation with Third Parties and Authorities

4.1 Tap Ease may cooperate with: (a) banks and payment processors; (b) card schemes; (c) government regulators and authorities; (d) law enforcement agencies.

4.2 Cooperation may include sharing information where required or authorised by law, or where reasonably necessary to manage risk or protect Tap Ease's legal interests.

5. Withholding, Delay and Restriction Measures

5.1 Tap Ease may, without notice: (a) delay or withhold settlements; (b) restrict transaction processing; (c) suspend or terminate Accounts; (d) require enhanced verification.

5.2 Such measures may be applied where Tap Ease reasonably identifies risk, suspected misuse, regulatory concern or breach of Associated Policies.

6. Confidentiality and Non-Disclosure

6.1 Tap Ease may be legally restricted from disclosing whether information has been provided to banks, regulators or authorities.

6.2 Users acknowledge that Tap Ease has no obligation to notify them of monitoring outcomes or regulatory communications.

7. No Guarantee of Availability or Processing

7.1 Compliance, monitoring and verification activities may result in delays or restrictions.

7.2 Tap Ease does not guarantee uninterrupted access, transaction approval or settlement timeframes.

8. No Liability

To the maximum extent permitted by law, Tap Ease is not liable for loss arising from compliance, monitoring, withholding or cooperation actions taken in good faith.

9. Amendments

Tap Ease may amend this Policy at any time by publishing an updated version on its website. Continued use constitutes acceptance.

Use of Tap Ease services constitutes acceptance of this Policy.