Refund Policy

1. Introduction

91 Payments Limited ("91 Payments", "we", "our", or "us") is a Canadian-registered Money Services Business (MSB) providing regulated payment processing, cross-border transfer services, foreign exchange services, and related financial solutions.

This Refund Policy sets out the conditions, eligibility requirements, procedures, limitations, and timelines applicable to refund requests relating to transactions processed through our systems.

Due to the nature of financial services and real-time settlement infrastructure, customers acknowledge that most transactions processed by 91 Payments Limited are final, irreversible, and immediately transmitted to financial networks or beneficiary institutions once executed.

This Policy is designed to ensure transparency, operational consistency, fraud prevention, and compliance with applicable Canadian regulatory requirements, including obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and supervisory expectations issued by the Financial Transactions and Reports Analysis Centre of Canada.

2. Purpose and Objectives of This Policy

The objectives of this Refund Policy include:

• Defining clear conditions under which refunds may or may not be granted
• Ensuring consistent and transparent handling of refund requests
• Protecting the integrity of financial settlement systems and partner institutions
• Preventing fraudulent, abusive, or unauthorized refund claims
• Ensuring compliance with AML/CFT, sanctions, and financial crime prevention obligations
• Providing customers with clarity on transaction finality and dispute limitations
• Supporting regulatory auditability and operational accountability

This Policy is part of our broader financial control and risk management framework and must be read in conjunction with our Terms of Service, AML/CFT Policy, and operational guidelines.

3. General Principles of Refund Processing

91 Payments Limited operates within regulated financial infrastructure where transactions are often processed through multiple intermediaries, including banks, payment processors, clearing systems, and correspondent networks.

Accordingly, the following principles apply:

• Transactions are generally considered final once successfully processed and transmitted
• Refunds are exceptional rather than standard practice
• All refund requests are subject to strict verification and compliance review
• Refund eligibility is determined on a case-by-case basis
• No refund is guaranteed unless explicitly confirmed in writing by the Company

Customers acknowledge that financial transactions may be subject to external banking systems beyond the control of 91 Payments Limited.

4. Eligibility for Refunds

Refunds may be considered only under the following limited and controlled circumstances:

5. Non-Refundable Transactions

Refunds will NOT be granted in the following circumstances:

6. Refund Request Submission Requirements

All refund requests must include:

• Full legal name of customer
• Transaction reference number
• Date and time of transaction
• Amount and currency
• Detailed reason for refund request
• Supporting documentation (where applicable)

We may also require:

• Government-issued identification
• Proof of payment source
• Additional verification documents for compliance purposes

Incomplete refund requests may be delayed or rejected.

7. Refund Review and Approval Process

All refund requests undergo a structured internal review process:

Refund approval is not automatic and may require escalation depending on risk classification.

8. Refund Timelines

If approved, refunds are typically processed within:

• 5 to 15 business days for domestic transactions
• 10 to 30 business days for international transactions

Delays may occur due to:

• Banking intermediary processing times
• Compliance reviews
• Cross-border settlement cycles
• Foreign exchange reconciliation

91 Payments Limited does not guarantee exact processing timelines where third-party institutions are involved.

9. Foreign Exchange (FX) Transaction Refunds

For FX-related transactions:

• Exchange rates are locked at the time of execution
• FX trades are generally irreversible once confirmed
• Refunds, if applicable, will be processed based on the prevailing market rate at the time of reversal
• Any FX loss or gain arising from reversal is not borne by 91 Payments Limited

10. Fraud, Unauthorized Access, and Disputed Transactions

Where a transaction is suspected to be fraudulent or unauthorized:

• The transaction may be temporarily frozen for investigation
• Internal fraud review procedures will be initiated
• Customers may be required to provide supporting evidence
• Law enforcement or regulatory authorities may be notified

Refunds in fraud cases are only issued where investigations confirm eligibility in accordance with applicable legal and regulatory frameworks.

11. Third-Party Banking and Settlement Systems

91 Payments Limited relies on third-party financial institutions for settlement. Accordingly:

• We are not responsible for delays or failures caused by external banks
• Refunds are subject to confirmation from intermediary institutions
• Returned funds must be fully received before refund processing begins

12. Account Verification Requirements for Refunds

Refunds may only be issued to:

• The original funding source
• A verified account belonging to the original customer
• Accounts that pass compliance verification checks

We reserve the right to refuse refunds to third-party accounts for security and AML reasons.

13. Fraud Prevention and Anti-Abuse Controls

To protect the integrity of our system, we actively monitor refund requests for:

• Repeated or excessive refund claims
• Fraudulent chargeback patterns
• Identity misrepresentation
• Abuse of dispute mechanisms

We reserve the right to:

• Decline refund requests
• Suspend accounts
• Report suspicious activity to FINTRAC or law enforcement

14. Limitation of Liability

91 Payments Limited shall not be liable for:

• Indirect or consequential losses
• Exchange rate fluctuations
• Banking system delays
• Errors caused by customer input
• Actions of third-party financial institutions

Our liability is strictly limited to the value of the original transaction where a refund is approved.

15. Policy Modifications

We may update or modify this Refund Policy at any time due to:

• Regulatory changes
• Operational improvements
• Risk management updates
• Industry best practices

The updated version will be published on our website with a revised effective date.

16. Contact Information

For refund inquiries or disputes:

91 Payments Limited

1771 Robson Street – 1311

Vancouver, British Columbia, Canada

Email: support@91-payments.com

Compliance: compliance@91-payments.com