Anti-Money Laundering (AML) Policy

1. Purpose
   
   The purpose of this Anti-Money Laundering (AML) Policy is to ensure compliance with all applicable laws and regulations regarding the prevention of money laundering and terrorist financing. This policy applies to all account holders, contractors, and agents of the company.
2. Key Principles
   
   
   • Customer Due Diligence (CDD): We will conduct thorough customer due diligence, including verifying the identity of customers, understanding the nature of customer relationships, and monitoring transactions to detect suspicious activities.
   • Record Keeping: We will maintain accurate and complete records of all transactions and customer due diligence activities for a minimum of five years.
   • Reporting: We will report any suspicious transactions to the relevant authorities in accordance with legal requirements.
   • Training: All account holders will receive regular training on AML policies and procedures.
3. Customer Identification Program (CIP)
   
   
   • New Customers: We will obtain, verify, and record information that identifies each person who opens an account. This includes name, address, date of birth, and identification number.
   • Existing Customers: We will periodically review and update customer information to ensure it remains accurate and relevant.
4. Monitoring and Reporting
   
   
   • Transaction Monitoring: We will monitor transactions to identify and report any that are unusual or suspicious.
   • Suspicious Activity Reporting (SAR): Any account holder who suspects money laundering or terrorist financing must report it immediately to the designated AML officer.
5. Account Holder Responsibilities
   
   
   • Compliance: All account holders must comply with this AML policy and report any violations.
   • Awareness: Account holders must be aware of the signs of money laundering and terrorist financing and understand their reporting obligations.
6. Sanctions and Penalties
   
   
   • Non-Compliance: Non-compliance with this AML policy may result in disciplinary action, including termination of the account.
   • Legal Consequences: The company may face legal consequences, including fines and reputational damage, for non-compliance with AML regulations.
7. Review and Updates
   
   
   • Periodic Review: This AML policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, and best practices.

By adhering to this AML policy, we aim to protect our company and its stakeholders from the risks associated with money laundering and terrorist financing.