Anti-Money Laundering Policy

venoPay maintains a zero-tolerance policy toward money laundering and terrorist financing. We are committed to complying with all applicable anti-money laundering (AML) laws and regulations in the jurisdictions where we operate.

We conduct thorough due diligence on all customers:

• Identity verification for all account holders
• Address verification and documentation
• Source of funds verification for large transactions
• Enhanced due diligence for high-risk customers
• Ongoing monitoring of customer activity

Our KYC procedures include:

• Collection of personal identification documents
• Verification through trusted third-party services
• Regular updates to customer information
• Risk assessment based on customer profile
• Enhanced verification for suspicious activity

We employ sophisticated systems to monitor transactions:

• Real-time monitoring of all transactions
• Automated alerts for suspicious patterns
• Manual review of flagged transactions
• Analysis of transaction history and trends
• Cross-referencing with sanction lists

We report suspicious activities as required by law:

• Filing Suspicious Activity Reports (SARs) with authorities
• Maintaining detailed records of suspicious transactions
• Cooperating fully with law enforcement
• Not disclosing SAR filings to account holders
• Regular review and update of reporting procedures

We maintain comprehensive records:

• Customer identification documents for 5 years after account closure
• Transaction records for 5 years
• Correspondence and account files
• Reports to regulatory authorities
• Internal investigation documentation

We pay special attention to potentially high-risk activities:

• Large cash transactions
• Rapid movement of funds
• Transactions to high-risk jurisdictions
• Unusual transaction patterns
• Transactions involving politically exposed persons (PEPs)

We screen all customers and transactions against:

• OFAC sanctions lists
• UN sanctions lists
• EU sanctions lists
• Other relevant government sanctions programs
• Politically exposed persons (PEP) databases

All venoPay employees receive regular AML training:

• Initial AML training upon employment
• Annual refresher courses
• Updates on regulatory changes
• Recognition of red flags and suspicious activity
• Proper reporting procedures

We have designated a Compliance Officer responsible for:

• Overseeing AML compliance program
• Investigating suspicious activity
• Filing required reports with authorities
• Maintaining relationships with regulators
• Regular policy review and updates

We conduct regular risk assessments to:

• Identify potential money laundering risks
• Evaluate effectiveness of controls
• Update policies and procedures
• Allocate resources appropriately
• Ensure ongoing compliance

We fully cooperate with law enforcement and regulatory agencies:

• Responding promptly to information requests
• Providing account and transaction information
• Freezing accounts when legally required
• Participating in investigations
• Implementing regulatory guidance