Anti-Money Laundering (AML) Policy

1. Purpose

This Anti-Money Laundering (AML) policy is designed to:

• Prevent and detect money laundering, terrorist financing, and other illegal financial activities.

• Establish guidelines to ensure compliance with relevant anti-money laundering regulations.

• Safeguard the company’s reputation by mitigating the risk of financial crime.

2. Scope

This AML policy applies to all employees, agents, and partners of [Your Company Name]. It governs all services, transactions, and client interactions where money laundering risks may arise.

3. Key Definitions

• Money Laundering: The process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.

• Terrorist Financing: The act of providing financial support to individuals or organizations involved in terrorist activities.

4. Policy Statement

[Your Company Name] is committed to full compliance with all applicable AML laws and regulations. All employees are expected to understand and abide by this policy to prevent the use of our services for money laundering or terrorist financing activities.

5. Customer Due Diligence (CDD)

To identify and verify the identity of our clients, we will:

• Collect personal identification information for individuals (e.g., full name, date of birth, national ID).

• Obtain business documentation for corporate clients (e.g., registration documents, directors’ list, beneficial owners).

• Perform enhanced due diligence on high-risk clients, including those in high-risk jurisdictions or politically exposed persons (PEPs).

6. Risk-Based Approach (RBA)

We implement a risk-based approach to manage money laundering risks, which involves:

• Assessing and categorizing clients based on their risk profile (low, medium, or high).

• Focusing additional resources on higher-risk clients and transactions.

• Reviewing the risk categorization periodically and updating it based on the client’s behavior or changes in their profile.

7. Monitoring and Reporting Suspicious Activities

• Transaction Monitoring: We continuously monitor transactions for unusual or suspicious patterns, such as large cash deposits, frequent high-value transactions, or transactions inconsistent with the client’s profile.

• Suspicious Activity Reporting (SAR): If suspicious activity is identified, a report will be submitted to the designated compliance officer, who will decide on filing a report with the relevant financial authorities as required by law.

• Record Keeping: All SARs, transaction records, and due diligence documentation will be securely stored for a minimum of five years.

8. Training and Awareness

• Employee Training: All employees will receive regular AML training, covering how to identify suspicious activities, file SARs, and apply due diligence procedures.

• Updates: Training will be updated periodically to reflect regulatory changes and emerging money laundering threats.

9. Record-Keeping

• Maintain detailed records of all transactions, client identification documents, and SARs for at least five years.

• Store records securely and make them accessible for audits, regulatory inquiries, and internal compliance checks.

10. Compliance Officer Responsibilities

A designated AML Compliance Officer will be responsible for:

• Overseeing the implementation of this policy.

• Monitoring compliance with AML laws and regulations.

• Reviewing and approving all SARs before submission to authorities.

• Providing regular AML reports to senior management.

11. Periodic Policy Review

• This AML policy will be reviewed and updated regularly to align with regulatory changes, emerging risks, and best practices in financial crime prevention.

12. Consequences of Non-Compliance

Employees who fail to comply with this AML policy may face disciplinary action, including termination. Non-compliance may also result in legal consequences for the company and involved individuals.