AML Policy

Anti-Money Laundering and Counter-Terrorist Financing Policy

Introduction

At LEVEL 9 ("Company," "we," "our," or "us"), we are dedicated to upholding the highest ethical standards and ensuring full compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws.

This Anti-Money Laundering Policy ("Policy") sets out the measures we take to prevent, detect, and report any suspicious activities related to money laundering or the financing of terrorism.

Our Objectives

  • Ensure compliance with AML/CTF regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and relevant international standards.
  • Prevent the misuse of our services for illegal activities.
  • Establish strong processes for verifying clients and monitoring transactions.
  • Report any suspicious activities to the proper authorities in a timely manner.
  • Promote a culture of awareness and compliance among our employees.

Who This Policy Applies To

This Policy covers:

  • All employees, contractors, and officers of LEVEL 9.
  • Clients, partners, and any other entities doing business with us.
  • All products, services, and financial transactions associated with LEVEL 9.

Understanding Money Laundering

Money laundering is the process of disguising illegally obtained funds to make them appear legitimate. It typically involves three stages:

  • Placement – Introducing illicit funds into the financial system.
  • Layering – Moving money through multiple transactions to obscure its origin.
  • Integration – Using the laundered funds in the economy as though they were legally earned.

Our AML Program

Know Your Customer (KYC)

Before doing business with us, all clients must go through a verification process. We collect and verify key details such as full name, date of birth, address, government-issued ID, and business ownership information. High-risk clients, including politically exposed persons (PEPs) and those from high-risk regions, undergo enhanced due diligence (EDD).

Transaction Monitoring

We monitor transactions for any unusual or suspicious activity. Transactions that do not align with a client's profile or expected behavior may be flagged for further review.

Record Keeping

We securely store all relevant client information, transactions, and communications for the legally required period. These records are available for regulatory audits and investigations.

Reporting Suspicious Activity

Any suspicious activities are promptly reported to the appropriate authorities, such as the Financial Crimes Enforcement Network (FinCEN). Employees are trained to recognize and report red flags, including unusual transaction patterns or inconsistent client behavior.

Prohibited Activities

LEVEL 9 strictly prohibits:

  • Engaging in or facilitating transactions linked to illegal activities.
  • Doing business with shell banks or entities that allow anonymous ownership.
  • Conducting transactions with individuals or entities on government sanctions or watch lists, such as those maintained by the U.S. Treasury's Office of Foreign Assets Control (OFAC) and the United Nations.

Roles & Responsibilities

AML Compliance Officer (AMLCO):

  • Oversees the implementation and enforcement of the AML program.
  • Provides training, assesses risks, and liaises with regulatory authorities.

Management:

  • Ensures the AML program is properly resourced and supported.

Employees:

  • Must understand and follow this Policy.
  • Are required to report any suspicious activity to the AMLCO immediately.

Client Cooperation

We require all clients to:

  • Provide accurate and up-to-date information during the onboarding process.
  • Notify us of any changes to their personal or business details.
  • Avoid engaging in any activities that may raise AML/CTF concerns.

Failure to comply with these requirements may result in account suspension, termination, or reporting to regulatory authorities.

Contact Information

For questions regarding this AML Policy, please contact our Compliance Department:

Email: [email protected]

Phone: +1 (555) LEVEL-9