AML/CTF Compliance Policy

 GFIS  LLC

AML/CTF Compliance Policy

Effective Date: 07/01/2025
Applicability: All employees, contractors, and third-party partners

1. Risk Assessment & Compliance Framework

  • Jurisdictional Risks: Due to cross-border transactions, the company will assess risks associated with:
    • High-risk countries (FATF black/grey lists).
    • Clients from sanctioned jurisdictions (OFAC, EU, UN lists).
    • Cryptocurrency or cash payments (if accepted).
  • Regulatory Obligations:
    • Comply with U.S. Bank Secrecy Act (BSA) and FinCEN requirements (even if operating overseas).
    • Follow FATF Recommendations for global AML/CFT standards.
    • Adhere to local AML laws in jurisdictions where banking occurs.

2. Customer Due Diligence (CDD)

A. Identification & Verification (KYC)

  • Individual Clients: Collect:
    • Full name, date of birth, nationality.
    • Government-issued ID (passport, driver’s license).
    • Proof of address (utility bill, bank statement).
  • Business Clients: Collect:
    • Certificate of incorporation/formation.
    • Beneficial ownership details (≥25% ownership).
    • Tax identification numbers (EIN, foreign equivalent).

B. Enhanced Due Diligence (EDD)
Apply EDD for:

  • PEPs (Politically Exposed Persons) and their associates.
  • Clients from high-risk jurisdictions.
  • Large or unusual transactions (e.g., over $10,000 in cash/virtual assets).

3. Ongoing Monitoring & Reporting

  • Transaction Monitoring:
    • Flag unusual patterns (e.g., rapid movement of funds, mismatched business activity).
    • Screen for sanctions lists (OFAC, UN, EU) daily.
  • Suspicious Activity Reports (SARs):
    • File SARs with FinCEN if U.S. nexus exists (e.g., U.S. clients, banks).
    • Report to local FIUs (Financial Intelligence Units) where required.

4. Multi-Currency & Overseas Banking Controls

  • Currency Acceptance Policy:
    • Only accept payments via traceable methods (bank transfers, PayPal, Stripe—no anonymous crypto).
    • Convert and hold funds in stable currencies (USD, EUR, GBP) where possible.
  • Overseas Bank Account Compliance:
    • Ensure foreign banks comply with FATCA (for U.S. reporting) and local AML laws.
    • Avoid jurisdictions with weak AML enforcement (e.g., tax havens without CRS participation).

5. Recordkeeping

  • Retain KYC documents, transaction records, and SARs for 5 years (minimum).
  • Store data securely with encryption and access controls.

6. Employee Training & Awareness

  • Annual AML/CTF training covering:
    • Red flags (e.g., layering, structuring, fake invoices).
    • Reporting obligations (SARs, sanctions screening).
  • Designate a Compliance Officer to oversee AML efforts.

7. Prohibited Activities

  • No dealings with:
    • Sanctioned individuals/entities.
    • Shell companies without legitimate business purposes.
    • Unregulated crypto exchanges.

8. Independent Audit

  • Conduct annual third-party audits to ensure policy adherence.

Implementation Notes for Remote Business Services LLC

  • Technology: Use AML software (e.g., ComplyAdvantage, LexisNexis) for real-time sanctions screening.
  • Banking Partners: Confirm overseas banks follow FATF Standards and have robust AML programs.
  • U.S. Compliance: Even if funds are held overseas, FinCEN reporting may apply if the company is U.S.-registered or serves U.S. clients.

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