Anti-Money Laundering Policy

1. Policy Statement

SmartPinvest Finance maintains a zero-tolerance policy toward money laundering and terrorist financing. We are committed to:

• Complying with all applicable AML laws and regulations
• Implementing robust customer due diligence procedures
• Monitoring transactions for suspicious activity
• Reporting suspicious transactions to relevant authorities
• Training our staff on AML requirements and procedures
• Maintaining comprehensive records as required by law
• Cooperating fully with law enforcement and regulatory authorities

2. Regulatory Compliance

Applicable Laws and Regulations

We comply with AML requirements under various jurisdictions, including:

• Bank Secrecy Act (BSA) - United States
• USA PATRIOT Act - United States
• Financial Action Task Force (FATF) recommendations
• Local AML laws in jurisdictions where we operate
• International sanctions and embargo programs

Regulatory Oversight

Our AML program is overseen by designated compliance officers and is subject to regular review by independent auditors and regulatory authorities.

3. Customer Identification Program (CIP)

Know Your Customer (KYC)

Before opening any account, we verify the identity of our customers by collecting:

• Personal Information: Full name, date of birth, address
• Identification Documents: Government-issued photo ID
• Proof of Address: Utility bills, bank statements
• Financial Information: Source of funds, income verification
• Business Information: For corporate accounts

Enhanced Due Diligence (EDD)

We apply enhanced due diligence for:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Customers with complex ownership structures
• Customers engaging in high-value transactions
• Customers with unusual transaction patterns

Ongoing Monitoring

We continuously monitor customer accounts and update customer information as necessary to ensure accuracy and completeness.

4. Transaction Monitoring

Automated Monitoring Systems

We employ sophisticated automated systems to monitor all transactions in real-time for patterns that may indicate money laundering or other suspicious activity.

Red Flags and Indicators

Our monitoring systems are designed to detect:

• Unusual transaction amounts or frequencies
• Transactions inconsistent with customer profile
• Rapid movement of funds between accounts
• Transactions involving high-risk jurisdictions
• Structured transactions to avoid reporting thresholds
• Transactions with sanctioned entities or individuals

Large Transaction Reporting

We maintain records of all transactions above regulatory thresholds and file Currency Transaction Reports (CTRs) as required by law.

5. Suspicious Activity Reporting

Identification and Investigation

When suspicious activity is detected, our compliance team conducts a thorough investigation to determine whether the activity warrants reporting to authorities.

Suspicious Activity Reports (SARs)

We file Suspicious Activity Reports with relevant authorities within required timeframes when we identify transactions that:

• Involve known or suspected money laundering
• Appear designed to evade reporting requirements
• Lack apparent business purpose
• Involve potential terrorist financing
• Violate federal or state laws

Confidentiality

All suspicious activity reports and related investigations are kept strictly confidential in accordance with applicable laws.

6. Record Keeping

Required Records

We maintain comprehensive records including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• Suspicious activity reports and investigations
• Currency transaction reports
• Correspondence with regulatory authorities
• AML training records

Retention Periods

Records are retained for the following minimum periods:

• Customer identification records: 5 years after account closure
• Transaction records: 5 years from transaction date
• Suspicious activity reports: 5 years from filing date
• Training records: 5 years from completion date

7. Training & Awareness

Staff Training

All employees receive comprehensive AML training covering:

• AML laws and regulations
• Company policies and procedures
• Red flags and suspicious activity indicators
• Reporting requirements and procedures
• Customer due diligence requirements
• Record keeping obligations

Ongoing Education

Training is updated regularly to reflect changes in laws, regulations, and emerging threats. All staff must complete annual refresher training.

8. Consequences of Non-Compliance

Account Actions

Customers who fail to comply with our AML requirements may face:

• Account restrictions or limitations
• Transaction monitoring and additional scrutiny
• Account closure and termination of services
• Reporting to law enforcement authorities
• Legal action as appropriate

Regulatory Penalties

We take our AML obligations seriously to avoid regulatory penalties including fines, sanctions, and loss of operating licenses.

9. Contact Information

For questions about our AML policy or to report suspicious activity: