Anti-Money Laundering Policy

1. Introduction

SollCard is committed to maintaining the highest standards of anti-money laundering (AML) compliance and preventing the use of our services for money laundering, terrorist financing, or other illicit activities. This AML Policy outlines our comprehensive approach to detecting, preventing, and reporting suspicious activities.

We operate in full compliance with applicable AML laws and regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and international standards set by the Financial Action Task Force (FATF).

2. Definitions

For the purposes of this AML Policy, the following definitions apply:

• "AML" means Anti-Money Laundering
• "BSA" means Bank Secrecy Act
• "CDD" means Customer Due Diligence
• "EDD" means Enhanced Due Diligence
• "FATF" means Financial Action Task Force
• "KYC" means Know Your Customer
• "MLRO" means Money Laundering Reporting Officer
• "PEP" means Politically Exposed Person
• "SAR" means Suspicious Activity Report
• "STR" means Suspicious Transaction Report

3. Compliance Framework

Our AML compliance framework is built on four key pillars:

3.1 Governance Structure

• Board-level oversight of AML compliance
• Dedicated AML compliance officer and team
• Regular risk assessments and policy reviews
• Independent compliance monitoring and auditing

3.2 Regulatory Compliance

• Full compliance with BSA and USA PATRIOT Act
• Adherence to FATF recommendations
• Compliance with state and federal regulations
• Regular regulatory reporting and filing

3.3 Technology and Systems

• Advanced transaction monitoring systems
• Automated screening and filtering tools
• Blockchain analytics and investigation tools
• Real-time risk scoring and alerting

3.4 Training and Awareness

• Comprehensive staff training programs
• Regular updates on regulatory changes
• Case studies and practical examples
• Certification and competency testing

4. Know Your Customer (KYC) Procedures

All customers must undergo comprehensive KYC verification before accessing our services:

4.1 Identity Verification

• Government-issued photo identification
• Biometric verification where applicable
• Document authenticity verification
• Identity cross-referencing with databases

4.2 Address Verification

• Proof of residential address
• Utility bills or bank statements
• Address verification through third-party services
• Geolocation verification for digital services

4.3 Source of Funds Verification

• Employment verification and income documentation
• Business ownership and financial statements
• Investment portfolio documentation
• Cryptocurrency transaction history analysis

4.4 Ongoing Monitoring

• Regular review of customer information
• Transaction pattern analysis
• Risk profile updates
• Periodic re-verification requirements

5. Customer Due Diligence (CDD) Requirements

We implement comprehensive CDD procedures for all customers:

5.1 Basic CDD Requirements

• Customer identification and verification
• Beneficial ownership identification
• Business relationship purpose assessment
• Ongoing monitoring of transactions

5.2 Customer Risk Profiling

• Geographic risk assessment
• Product and service risk evaluation
• Customer type and behavior analysis
• Delivery channel risk assessment

5.3 Documentation Requirements

• Complete customer information forms
• Supporting documentation collection
• Verification of information accuracy
• Regular documentation updates

6. Enhanced Due Diligence (EDD) Requirements

Enhanced due diligence is required for high-risk customers and transactions:

6.1 High-Risk Customer Categories

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

6.2 EDD Procedures

• Additional identity verification steps
• Enhanced source of funds verification
• Senior management approval requirements
• Increased monitoring and reporting

6.3 Ongoing EDD Monitoring

• More frequent transaction reviews
• Enhanced screening and filtering
• Regular risk assessment updates
• Specialized investigation procedures

7. Transaction Monitoring and Screening

We employ sophisticated systems to monitor and screen all transactions:

7.1 Automated Monitoring Systems

• Real-time transaction analysis
• Pattern recognition and anomaly detection
• Risk scoring and alert generation
• Automated blocking of suspicious transactions

7.2 Screening Procedures

• Sanctions list screening
• PEP database screening
• Adverse media monitoring
• Watchlist and blacklist checking

7.3 Manual Review Process

• Expert analyst review of alerts
• Case investigation and documentation
• Decision making and escalation procedures
• Quality assurance and feedback loops

8. Suspicious Activity Reporting

We maintain robust procedures for identifying and reporting suspicious activities:

8.1 Suspicious Activity Indicators

• Unusual transaction patterns or volumes
• Transactions inconsistent with customer profile
• Rapid movement of funds without apparent purpose
• Use of multiple accounts or complex structures
• Transactions involving high-risk jurisdictions

8.2 Reporting Procedures

• Immediate identification and escalation
• Comprehensive investigation and documentation
• Timely filing of SARs with FinCEN
• Coordination with law enforcement when appropriate

8.3 SAR Filing Requirements

• Filing within 30 days of detection
• Comprehensive documentation and evidence
• Accurate and complete information
• Confidentiality and non-disclosure compliance

9. Record Keeping Requirements

We maintain comprehensive records in compliance with regulatory requirements:

9.1 Record Types

• Customer identification and verification records
• Transaction records and supporting documentation
• Correspondence and communication records
• Investigation and case management files

9.2 Retention Periods

• Customer records: 5 years after account closure
• Transaction records: 5 years from transaction date
• SARs and supporting documentation: 5 years from filing date
• Training records: 3 years from completion date

9.3 Record Security

• Secure storage and access controls
• Regular backup and disaster recovery procedures
• Confidentiality and privacy protection
• Audit trail and access logging

10. Staff Training and Awareness

All staff receive comprehensive AML training and regular updates:

10.1 Training Program Components

• AML laws and regulations overview
• Customer due diligence procedures
• Transaction monitoring and screening
• Suspicious activity identification and reporting
• Case studies and practical examples

10.2 Training Frequency

• Initial training for all new employees
• Annual refresher training for all staff
• Specialized training for compliance personnel
• Updates following regulatory changes

10.3 Training Effectiveness

• Competency testing and certification
• Performance monitoring and feedback
• Training program evaluation and improvement
• Documentation of training completion

11. Risk Assessment

We conduct regular risk assessments to identify and mitigate AML risks:

11.1 Risk Categories

• Customer risk (geographic, demographic, behavioral)
• Product and service risk
• Geographic and jurisdictional risk
• Operational and technological risk

11.2 Risk Mitigation

• Enhanced due diligence for high-risk customers
• Increased monitoring and screening
• Restricted services for certain risk categories
• Regular policy and procedure updates

12. Contact Information

For questions about this AML Policy or to report suspicious activities, please contact:

This AML Policy is effective as of January 1, 2024, and was last updated on January 1, 2024.