AML & COMPLIANCE POLICY

OUR AML POLICY

As a Money Service Business, we must always comply with all States and Federal laws and recommendations regarding money transfer. What follows is a non-exhaustive list of regulations we are subject to.

Reporting

We are required to report the following types of transactions to the authorities:

Suspicious Activities
Large funds transfers

Record Keeping

We are required to keep all customer identifications, transaction information, and corporate records for a minimum of 5 years.

Ascertaining Identity

We are required to collect and verify the customer’s identification for a funds transfer of 3,000 USD and more.

Politically Exposed Person (PEP)

We are required to make PEP determination for transactions that have any ties to politically exposed persons.

Third Party Determination

If someone is conducting a transaction on someone else’s behalf, we are required to obtain information on both parties: the agent and the principal.

Compliance Program

We are required to maintain a compliance program containing adequate policies and procedures in accordance with the applicable regulations. For more information, refer to FinCEN Website: http://www.fincen.gov/financial_institutions/msb/.

ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING

We take the following additional measures to prevent money laundering and terrorist financing:

Scanning Against Global Sanction Lists

We partnered with Smart Search LLC, to perform a prior deeper screening on customers who request transfer large amount of funds. several sanction lists – including US Treasury watch list (OFAC), UN, EU, CA, and UK sanction lists.

Transaction Monitoring

We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:

Client Profiling
Risk Assessment
Client Identification Controls & Validations
Transaction Aggregation Thresholds
Government Reporting Controls & Validations
Possible Structuring Reporting
Enhanced Due Diligence Reporting

Information about the Source of Funds

We may request additional information from the customer about the source of funds, prior to the funds being sent. Failure to meet this request will result in customer’s account being either suspended or closed, and funds being returned.