ANTI-MONEY LAUNDERING POLICY

This Anti-Money Laundering policy (hereinafter referred to as” Policy”) is effective from [INSERT DATE ON WHICH THE AGREEMENT COMES INTO FORCE] and applies to all employees and members of the [INSERT COMPANY NAME] (hereinafter referred to as “Us” or “we” or “our” or “Company”).

Persons availing of the any services from Company, or engaging in any transactions on any digital/non digital platform (the “Platform”) provided or operated by Company, directly or indirectly, are referred to herein, as “Users” or “Customers”.

This policy outlines the security measures and best practices to safeguard our company from money laundering and other financial crimes. Our Company is committed in safeguarding the Company’s financial system from illegal activities and ensures transparency in all financial transactions.

1. DEFINITIONS
   1. “Applicable Law” means all laws in force for the time being within the United States of America such as Bank Secrecy Act and regulatory requirements set forth by the Financial Crimes Enforcement Network (FinCEN) and other relevant authorities in the United States.
2. PURPOSE
   1. The purpose of this policy is to establish clear guidelines to prevent and detect activities related to money laundering and the financing of terrorism. This policy outlines procedures, responsibilities and controls that our Company will implement to ensure compliance with applicable Anti-Money laundering laws and regulations.
3. SCOPE
   1. This policy applies to all the Users of the Company’s Platform including the Company’s employees, contractors, customers or any individual with whom company’s financial information is being maintained, distributed or stored within the Company.
4. AML COMPLIANCE OFFICER
   1. A designated AML Compliance Officer will be appointed to oversee and enforce the AML program. The Compliance Officer will be responsible for staying informed about relevant AML laws and regulations, updating policies and procedures as necessary, and ensuring the implementation of effective AML measures.
5. CUSTOMER DUE DILIGENCE(CCD)
   1. Our Company will conduct CCD procedures, to assess and manage risks associated with our users. Our Company will identify all users before establishing a business relationship or conducting any transactions with the customers. This includes individuals, legal entities, and beneficial owners.
   2. Customer Identification Program (CIP): We have a comprehensive CIP to verify the identity of users or customers during the account registration process. This includes collecting and verifying customer information, such as name, address, date of birth, and other relevant details.
   3. Enhanced Due Diligence (EDD): We conduct enhanced due diligence on high-risk customers, including but not limited to, politically exposed persons (PEPs) and customers with large transactions. EDD may involve additional documentation, monitoring, and periodic reviews.
   4. Ongoing Monitoring: Implement a robust system for ongoing customer monitoring to detect and report suspicious activities. This includes monitoring transactions, account behavior, and changes in customer profiles.
6. TRANSACTION MONITORING AND REPORTING
   1. Transaction Monitoring System: We have a transaction monitoring system to identify and analyze unusual or suspicious transactions. This system should be regularly updated to adapt to emerging threats and regulatory changes.
   2. Currency Transaction Reports (CTRs): We report to FinCEN all currency transactions over $10,000 in a single day by a single customer, as required by the Bank Secrecy Act (BSA).
   3. Suspicious Activity Reports (SARs): We file SARs for any transactions or activities that appear suspicious or indicative of money laundering or terrorist financing, in accordance with regulatory requirements.
7. RISK ASSESSMENTS
   1. The Company will conduct Risk Assessments to identify and evaluate the money laundering activities within the Company.
   2. The Compliance team will analyze and document all the potential risks associated within and outside the Company and will take necessary steps to mitigate those money laundering risks.
   3. The Risk Management team will monitor regular updates and conduct Risk Assessments to mitigate those risks.
8. ANTI-MONEY LAUNDERING TRAINING
   1. All Employees working within the Company will receive appropriate training to recognize and become aware of the risks associated with money laundering, terrorist financing and other financial crimes.
   2. Employees will be trained in the procedure for customer due-diligence and know your customer, including customer identification and verification.
9. RECORD-KEEPING
   1. All information collected during KYC and CDD, including customer identification records and monitoring records will be maintained securely and retained in accordance with regulatory requirements.
   2. Confidential information should only be collected for specific, legitimate purposes and should not be used or disclosed for other purposes without obtaining consent, unless required by law.
   3. Access to personal information during KYC and CDD should be restricted to authorized personnel on a need-to-know basis.
10. CONFIDENTIALITY, INFORMATION SECURITY, PROPRIETARY INFORMATION AND INTELLECTUAL PROPERTY
    1. We are committed to business information confidentiality, integrity and accessibility, we implement proper technical security measures this and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorized parties. All members must handle any such information as secret. It also covers that, no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have impact on the securities. Every rule ensuring information security must be followed all times.
    2. Employees must maintain the confidentiality of the company and information. Sharing sensitive information with unauthorized individuals is strictly prohibited.
11. COMPLIANCE
    1. Compliance with this policy and applicable anti-money laundering laws should be regularly monitored and audited to identify and address any potential gaps or non-compliance.
    2. Any identified breaches or non-compliance should be promptly investigated and appropriate corrective actions should be taken.
12. CHANGES TO THE POLICY
    1. We reserve to right to update and make changes to this policy from time to time based on the working conditions of the Company. The Company on updating this policy will inform the members of the Company.
13. FURTHER INFORMATION
    1. For any queries or further Information regarding our Company or about this Policy, the concerned person can contact us through email [INSERT EMAIL ADDRESS OF THE COMPANY]
14. ACKNOWLEDGEMENT
    1. We expect all employees to adhere to this policy of the Company. The Company will apply this policy consistently and fairly to ensure a harmonious and productive workplace for all.
    2. By signing below, you acknowledge that you have carefully read and understood the terms and contents of this policy.
    3. You acknowledge that you will follow the set guidelines of this policy as well as of the Company and failure to do so; the Company can take Disciplinary action against such person.

COMPANY                  

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