Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy

Secure1, LLC Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy

  1. Introduction

    Secure1, LLC is committed to complying with all applicable laws and regulations related to Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF). This includes adherence to the guidelines set forth by the state of California and federal laws. This policy outlines the company's commitment to prevent, detect, and report any activities that may involve money laundering or financing of terrorism.

  2. Policy Statement

    Secure1, LLC is committed to implementing and maintaining a robust AML and CTF program to ensure compliance with all applicable laws and regulations. This includes the establishment of internal controls, ongoing employee training, independent audits, and the appointment of a designated AML Compliance Officer.

  3. AML Compliance Officer

    Secure1, LLC will appoint a designated AML Compliance Officer responsible for overseeing the implementation of the AML and CTF program and ensuring its effectiveness. The AML Compliance Officer will also be responsible for reporting any suspicious activities to the relevant authorities.

  4. Employee Training

    All employees will undergo regular training to understand the risks associated with money laundering and terrorism financing, and to recognize potential signs of suspicious activity. This training will be updated regularly to reflect changes in regulations and emerging risks.

  5. Customer Due Diligence

    Secure1, LLC will implement a comprehensive customer due diligence (CDD) process to verify the identity of all customers and assess their risk profile. This will include the collection and verification of customer identification data, understanding the nature of the customer's activities, and ongoing monitoring of customer transactions.

  6. Monitoring and Reporting

    Secure1, LLC will monitor all transactions to identify any unusual or suspicious activity. Any such activity will be reported to the relevant authorities in accordance with applicable laws and regulations.

  7. Record Keeping

    Secure1, LLC will maintain all records related to customer identification, transactions, and reports made to authorities for a minimum of five years. These records will be made available to authorities upon request.

  8. Penalties for Non-Compliance

    Non-compliance with this policy and applicable AML and CTF laws and regulations may result in severe penalties, including fines and imprisonment. All employees are expected to comply with this policy and report any suspicious activity to the AML Compliance Officer.