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Lawful Commerce & Compliance

Effective Date: April 7, 2025

ShotPay, LLC (“ShotPay”) is committed to operating in full compliance with all applicable federal, state, and local laws governing the sale, transfer, and financing of firearms, ammunition, and related products. This page describes our compliance philosophy, policies, and obligations with respect to lawful commerce in the shooting, hunting, outdoor, and tactical market.

1. Scope of ShotPay's Services

ShotPay provides consumer financing exclusively for lawful commerce in the shooting, hunting, outdoor, and tactical market. ShotPay does not finance, facilitate, or support any transaction that is unlawful under federal, state, or local law.

ShotPay is a payment and financing platform — we are not a federally licensed firearms dealer (FFL) and do not take physical possession of any firearm. All firearms transactions financed through ShotPay must be conducted through a properly licensed FFL dealer in compliance with federal and applicable state law.

2. Federal Firearms Laws

All transactions involving firearms financed through ShotPay must comply with applicable federal law, including:

The Gun Control Act of 1968 (18 U.S.C. § 921 et seq.), as amended;

The Brady Handgun Violence Prevention Act, requiring background checks through NICS for covered transactions;

The Protection of Lawful Commerce in Arms Act (PLCAA); and

All regulations promulgated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

3. State Law Compliance

In addition to federal law, firearms transactions are subject to the laws of the state in which the transaction occurs. ShotPay operates only in states where it holds applicable licenses or qualifies under applicable exemptions. Merchants and consumers are solely responsible for compliance with all applicable state and local laws, including waiting periods, state background check requirements, assault weapon restrictions, and magazine capacity limits.

ShotPay does not offer financing services in California or New York.

4. Prohibited Transactions

ShotPay strictly prohibits financing for:

Any item that is illegal for the purchaser to own or possess under applicable federal, state, or local law;

Straw purchases (purchasing a firearm or other item on behalf of a person who is prohibited from purchasing it directly);

Any transaction involving a prohibited person as defined under 18 U.S.C. § 922(g);

Unlicensed dealing in firearms; and

Any other transaction that violates applicable law.

ShotPay reserves the right to decline, cancel, reverse, or report any transaction we reasonably believe violates applicable law or our compliance policies.

5. Merchant Compliance Obligations

Merchants participating in the ShotPay platform agree to:

Maintain all required federal, state, and local licenses and permits (including FFL, where applicable);

Conduct all required background checks through NICS or applicable state equivalents;

Comply with all ATF recordkeeping requirements;

Not sell, transfer, or deliver any item to a purchaser who is prohibited by law from receiving it; and

Promptly notify ShotPay of any regulatory investigation or inquiry related to a transaction financed through ShotPay.

6. AML and KYC

ShotPay maintains a risk-based AML compliance program consistent with applicable financial laws and regulations. As part of our KYC process, ShotPay verifies the identity of all consumers before approving financing, in accordance with applicable regulations. ShotPay reserves the right to report suspicious activity to appropriate authorities as required by law.

Note: ShotPay does not operate in California. California Consumer Privacy Act (CCPA) rights do not apply to ShotPay’s activities.

7. Reporting and Cooperation

ShotPay cooperates fully with law enforcement and regulatory agencies in connection with lawful investigations. We maintain transaction records as required by applicable law and will produce such records in response to valid legal process.

8. Compliance Contact

ShotPay, LLC — Compliance

compliance@shotpay.com · New Braunfels, Texas