ANTI-MONEY LAUNDERING (AML) POLICY
Codeideas.dev. Effective Date: July 3rd, 2024
INTRODUCTION
1.1 Purpose: This Anti-Money Laundering (AML) Policy ("Policy") is established to prevent money laundering and terrorist financing through [Software Agency Name]'s ("the Company") financial transactions, including the receipt of funds and donations.
1.2 Scope: This Policy applies to all employees, contractors, partners, and agents of the Company involved in financial transactions.
DEFINITIONS
2.1 "Money Laundering" means the process of disguising the proceeds of crime to conceal their illegal origin.
2.2 "Terrorist Financing" means the financing of terrorist acts, terrorists, and terrorist organizations.
2.3 "Suspicious Activity" means any activity that appears unusual or potentially indicative of money laundering or terrorist financing.
RISK ASSESSMENT
3.1 The Company shall conduct regular risk assessments of clients, donors, and transactions.
3.2 The Company shall identify and document high-risk countries, individuals, and transaction types.
CUSTOMER DUE DILIGENCE (CDD)
4.1 The Company shall verify the identity of all clients and donors before engaging in any financial transaction.
4.2 For high-risk transactions, the Company shall conduct Enhanced Due Diligence (EDD).
TRANSACTION MONITORING
5.1 The Company shall implement an automated system to flag suspicious transactions.
5.2 The criteria for suspicious transactions shall be regularly reviewed and updated.
REPORTING
6.1 The Company shall appoint an AML Compliance Officer responsible for overseeing the implementation of this Policy.
6.2 The Company shall establish clear procedures for reporting suspicious activities internally.
6.3 The AML Compliance Officer shall file Suspicious Activity Reports (SARs) with the appropriate authorities as required by law.
RECORD KEEPING
7.1 The Company shall maintain all transaction records for a minimum of five (5) years.
7.2 The Company shall ensure proper documentation of all CDD and EDD processes.
TRAINING
8.1 The Company shall provide regular AML training to all relevant staff.
8.2 Training materials shall be kept up-to-date with current regulations.
COMPLIANCE REVIEW
9.1 The Company shall conduct annual internal audits of AML procedures.
9.2 The Company shall engage external auditors periodically to review the AML program.
SANCTIONS SCREENING
10.1 The Company shall screen all clients, donors, and transactions against relevant sanctions lists.
POLICY UPDATES
11.1 This Policy shall be reviewed and updated annually or as regulations change.
ENFORCEMENT
12.1 Failure to comply with this Policy may result in disciplinary action, up to and including termination of employment or business relationship.
GOVERNING LAW
13.1 This Policy shall be governed by and construed in accordance with the laws of Guatemala.
IN WITNESS WHEREOF, this Policy has been adopted by CodeIdeas.dev on 3rd of July 2024.
Jose Paiz. CEO