PassCash - Anti Money Laundering | Digital Payments & Solustions

Anti-Money Laundering (AML) Policy for PassCash

1. Purpose

The purpose of this AML Policy is to establish robust procedures to detect, prevent, and report money laundering, terrorist financing, and other illicit financial activities. PassCash is committed to complying with all applicable AML laws and regulations in the jurisdictions where we operate, including the Caribbean and Florida.

2. Scope

This policy applies to all employees, officers, directors, contractors, agents, and any third parties associated with PassCash. It also extends to all customers and transactions facilitated through our platform.

3. Objectives

Ensure compliance with AML laws and regulations. Prevent PassCash from being used for money laundering or terrorist financing. Identify and report suspicious activities in a timely manner. Establish a risk-based approach for customer due diligence (CDD) and transaction monitoring. Foster a culture of compliance within PassCash.

4. Key AML Measures

4.1. Customer Due Diligence (CDD)

PassCash requires identification and verification of all customers before providing services:

Individuals: Collect and verify full name, address, date of birth, and government-issued ID. Businesses: Verify legal name, registration details, business address, and authorized signatories. Enhanced Due Diligence (EDD): For high-risk customers such as politically exposed persons (PEPs) or customers from high-risk countries.

4.2. Know Your Customer (KYC) Requirements

PassCash follows a comprehensive KYC process:

Collect government-issued identification (e.g., passports, national IDs). Obtain proof of address (e.g., utility bills, bank statements). Verify beneficial ownership for business accounts. Conduct periodic reviews of customer information to ensure accuracy.

4.3. Monitoring Transactions

PassCash employs ongoing transaction monitoring to detect unusual patterns, including:

Large or repeated cash transactions. Transfers involving high-risk countries or entities. Transactions inconsistent with the customer's known profile.

4.4. Politically Exposed Persons (PEPs)

PassCash identifies and monitors accounts linked to PEPs. Additional safeguards include:

Enhanced due diligence during onboarding. Continuous monitoring of transactions. Escalating PEP-related transactions for Compliance Officer review.

4.5. Sanctions Screening

PassCash screens all customers and transactions against global watchlists, including:

OFAC (Office of Foreign Assets Control) lists. UN Security Council sanctions lists. Local and regional sanctions lists in the jurisdictions we operate.

4.6. Suspicious Activity Reporting (SAR)

PassCash is committed to identifying and reporting suspicious activities:

Filing SARs with the relevant Financial Intelligence Unit (FIU) if money laundering or terrorist financing is suspected. Maintaining confidentiality of SARs to protect the integrity of the investigation.

4.7. Record Keeping

PassCash will maintain records for at least five years, including:

Customer identification documents. Transaction histories. Correspondence and reports related to AML compliance.

4.8. Third-Party Vendor and Partner Due Diligence

PassCash evaluates third-party vendors, agents, and partners for AML compliance. This includes:

Verifying their AML policies and procedures. Monitoring their activities for potential risks.

4.9. Employee Training

All employees undergo regular AML training to:

Recognize suspicious activities. Understand legal and regulatory obligations. Stay updated on AML practices and regulatory changes.

5. Risk-Based Approach

PassCash adopts a risk-based approach to AML compliance:

Low-Risk Customers: Standard due diligence. High-Risk Customers: Enhanced due diligence, including additional verification steps and continuous monitoring. Risk assessments are conducted regularly to ensure appropriate mitigation measures.

6. Governance

6.1. AML Compliance Officer

PassCash has designated an AML Compliance Officer responsible for:

Overseeing AML compliance. Conducting audits and risk assessments. Reporting suspicious activities to regulatory authorities.

6.2. Reporting Structure

Employees are required to report any suspicious activities to the AML Compliance Officer immediately. The Compliance Officer will review and escalate matters as needed.

6.3. Internal Whistleblowing

Employees can report AML violations or concerns internally without fear of retaliation, ensuring transparency and accountability.

7. Technology and Automation

PassCash utilizes technology to enhance AML compliance:

Automated KYC verification tools for onboarding. AI-powered transaction monitoring systems to detect anomalies. Sanctions screening tools to ensure compliance with global regulations.

8. Cross-Border Activities

PassCash complies with AML laws in all jurisdictions where we operate, including:

U.S. regulations such as the Bank Secrecy Act. Caribbean Financial Action Task Force (CFATF) standards. FATF recommendations for combating money laundering and terrorist financing.

9. Penalties for Non-Compliance

Non-compliance with this policy or applicable AML regulations may result in:

Disciplinary action, including termination of employment or partnerships. Regulatory penalties and reputational damage to PassCash.

10. Updates and Review

This AML Policy will be reviewed annually or as required by changes in laws, regulations, or business practices.

Acknowledgment

All employees, contractors, and partners must acknowledge and adhere to this policy. Failure to do so will result in disciplinary measures.

Updates: