Introduction

This Risk Management Policy outlines the framework and procedures implemented by Stable Payments Inc. ("Autospend") to identify, assess, monitor, and mitigate risks associated with our cross-border payment services and operations.

Policy Objectives

• Identify and assess potential risks to the business and customers
• Implement controls to mitigate identified risks
• Monitor risk indicators and adjust strategies as needed
• Ensure compliance with regulatory requirements
• Protect the company's reputation and financial stability
• Safeguard customer assets and information

Risk Governance Structure

Board of Directors

• Oversees overall risk management strategy
• Reviews and approves risk policies
• Monitors significant risk exposures

Risk Management Committee

• Implements risk management framework
• Conducts regular risk assessments
• Reviews risk reports and metrics
• Recommends risk mitigation strategies

Types of Risks

Financial Risk

Includes market risk, currency risk, cryptocurrency volatility, and liquidity risk. Mitigated through use of stablecoins, real-time conversion, diversification of liquidity providers, and maintenance of adequate reserves.

Credit Risk

Risk of counterparty default, merchant insolvency, and chargeback exposure. Mitigated through comprehensive KYC/KYCB verification, credit assessment, transaction limits, and reserve requirements.

Operational Risk

System failures, processing errors, and third-party failures. Mitigated through redundant systems, automated processing, regular maintenance, employee training, and business continuity plans.

Compliance and Legal Risk

Non-compliance with AML/CFT/CPF regulations and data protection laws. Mitigated through comprehensive compliance programs, sanctions screening, regular audits, and monitoring of regulatory changes.

Fraud and Security Risk

Payment fraud, identity theft, cyberattacks, and money laundering. Mitigated through multi-factor authentication, fraud detection algorithms, transaction monitoring, encryption, and security assessments.

Reputational Risk

Negative publicity, customer complaints, and service disruptions. Mitigated through high customer service standards, transparent communication, and strict merchant vetting.

Risk Assessment Process

• Risk Identification: Regular workshops, incident analysis, and industry trend review
• Risk Analysis: Assessment of likelihood and impact, risk scoring and prioritization
• Risk Evaluation: Comparison against risk appetite and cost-benefit analysis
• Risk Treatment: Avoid, reduce, transfer, or accept risks as appropriate

Transaction Monitoring

• Automated screening of all transactions
• Sanctions list checking (OFAC, UN, EU)
• PEP and adverse media screening
• Transaction limits based on risk profile
• Machine learning for anomaly detection
• Suspicious Activity Report (SAR) filing when required

Key Risk Indicators

• Transaction failure rates
• Chargeback ratios
• Fraud detection rates
• System uptime and availability
• Compliance violations
• Customer complaint rates

Incident Management

All risk incidents are documented, investigated, and reported to the Risk Management Committee. Lessons learned are incorporated into risk mitigation strategies.

Policy Review

This Risk Management Policy is reviewed annually and updated as needed to reflect changes in the business, regulatory environment, or risk landscape.

Contact Information

For questions about risk management, contact us at: [email protected]