PagAmerican Platform Prohibited and Restricted Products Policy

This policy outlines the categories of products that are strictly prohibited from being sold through the PagAmerican platform. The objective is to ensure compliance with applicable laws and regulations, protect consumer safety, and maintain the integrity of our payment infrastructure.

This policy applies to all business lines, employees, contractors, agents, and affiliates of PagAmerican LLC. It covers all activities related to merchant onboarding, transaction processing, and ongoing monitoring of account activity.

PagAmerican LLC operates as a Merchant of Record and, based on current regulatory analysis, is not required to register as a Money Services Business (MSB) with FinCEN, as it does not engage in activities classified as money transmission under U.S. federal law.

However, PagAmerican remains fully committed to complying with:

• All applicable federal, state, and local laws in the United States;
• Regulatory requirements enforced by agencies such as FinCEN, the Federal Trade Commission (FTC), FDA, and others as relevant;
• Applicable international standards where merchants operate, including consumer protection, data privacy, and e-commerce regulation;
• Internal compliance procedures, including AML, chargeback risk mitigation, and fraud prevention protocols.

The sale of the following products is strictly prohibited. If a violation is identified, PagAmerican may, at its sole discretion, suspend transactions, withhold funds, and terminate the merchant account. We also reserve the right to report any illegal activity to the relevant authorities.

PagAmerican reserves the right to:

• Request additional documentation to validate operations;
• Withhold funds or suspend withdrawals in case of suspected violations;
• Terminate merchant accounts without prior notice;
• Report violations to relevant regulators and law enforcement agencies.

PagAmerican utilizes a combination of automated systems and manual review processes to continuously monitor merchant activity and protect the platform. These controls include:

• Real-time transaction monitoring for fraud detection, chargeback trends, and prohibited behavior;
• Merchant risk scoring based on product category, refund rates, complaint ratios, and behavioral patterns;
• Website and ad creative reviews to ensure transparency and regulatory compliance;
• Periodic re-evaluation of higher-risk merchants and continuous surveillance of flagged accounts.

To remain eligible on the PagAmerican platform, all merchants are expected to:

• Maintain truthful, complete, and up-to-date product information and refund policies;
• Respond in a timely manner to any customer dispute, inquiry, or complaint;
• Cooperate fully with compliance audits or any document request by PagAmerican or its financial partners;
• Promptly report any changes in product types, marketing models, fulfillment processes, or ownership structure.

Non-compliance may result in corrective actions, including temporary account suspension or permanent termination.

PagAmerican reserves the right to:

• Audit merchant activities in cases of unusual volume spikes, chargeback surges, or policy violations;
• Conduct enhanced due diligence using external data providers when needed;
• Share information with acquiring banks, card networks, regulators, or law enforcement agencies, as permitted by law.