It is the policy of IRIS CASH LLC. (the “ Company  ”) comply with the “Money Laundering (Prevention) Act 2011”.

This policy statement is an integral part of IRIS CASH LLC’s Anti-Money Laundering Policy, which includes the procedures and personnel responsible for complying with this policy and applicable laws.

Policy Reason/Purpose

The purpose of this policy is to ensure IRIS CASH LLC’s compliance. with anti-money laundering laws and regulations, assisting law enforcement in combating illegal money laundering, and minimizing the risk that IRIS CASH LLC resources. are used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties for IRIS CASH LLC. and/or individual employees and directors.

Who needs to know about this policy

All IRIS CASH LLC Personnel, Management and Directors must be aware of this policy.

Policy/Procedures

Money laundering is the process of concealing the existence, illegal source, or application of proceeds derived from criminal activity and subsequently disguising the source of those proceeds to appear legitimate. IRIS CASH LLC is committed to helping the Financial Intelligence Unit detect, prevent and eradicate the financing of terrorism and terrorist and criminal activity. IRIS CASH LLC. will evaluate all financial transactions and will take all necessary measures to comply with the laws and regulations against money laundering, detailed in the Company’s Policies and Procedures Manual.

Client Identification Procedures

As part of IRIS CASH LLC.’s AML policy, the Company has established procedures to ensure that the identities of all customers are verified before opening an account. Before opening an account for an individual client, IRIS CASH LLC. will require satisfactory documentary evidence of the customer’s name, address, date of birth and, among others, the following forms of identification:

1. ID and passport number
2. Driver’s license
3. Letter of reference (one from a company or financial institution and one professional/commercial reference).
4. Cross-checking (Global Compliance, Office of Foreign Assets Control, etc.)

For a corporation or other legal entity, IRIS CASH LLC. will require satisfactory legal evidence of the name of the entity, address and that the beneficiary and the operators have been duly authorized to open the account. The AML Compliance Officer will keep records of all documentation relied upon to identify the client/corporation.

Forbidden Client

IRIS CASH LLC. You will not open accounts or accept funds or securities from, or on behalf of, any person or entity or accept high-risk clients (with respect to money laundering or terrorist financing) without conducting well-documented and enhanced due diligence with respect to to said prospective customer.

Training and Review

The AML Compliance Officer will conduct semi-annual employee training programs for all staff regarding the AML policy. Such training programs will review applicable laws and regulations and recent trends in money laundering as it relates to the business of IRIS CASH LLC. Attendance at these programs is mandatory for all staff, and session and attendance records will be kept for a period of three years.

Who approved this policy

Board of Directors – IRIS CASH LLC.

INTRODUCTION

The prevention of money laundering in Colombia is governed by the Law on Assets of Crime (Money Laundering) and Financing of Terrorism (SC 2000, c. 17). This document is available to all staff. Staff must review the information contained in these documents, as well as these internal guidelines at least quarterly. The Company’s internal guidelines also adopt international best standards, including the anti-money laundering objectives of Section 313(a) and 319(b) of the USA Patriot Act of 2001 without incorporating foreign laws into the US general banking regimes or IRIS CASH LLC. ., for the Company to comply with its US correspondents.

These anti-money laundering provisions are designed to comply with international standards and have been unanimously adopted and approved by the Board of Directors at a Board meeting held on December 10, 2021 and will be updated and applied through the committee of executive management comprised of representatives of the Board along with the President, Chief Operating Officer and Chief Compliance Officer of the Company, who will report directly to the Chief Operating Officer and the President of the Company on all compliance matters Section 2(1) of The Colombian Law on Proceeds of Crime (Money Laundering) and Financing of Terrorism (SC 2000, c. 17) defines “money laundering” as:

• Participating, directly or indirectly, in a transaction involving property that is the proceeds of crime, knowing or having reasonable grounds to believe that such property is the proceeds of crime.
• Receive, possess, manage, invest, conceal, disguise, dispose of or bring into USA any property that is the proceeds of crime, knowing or having reasonable grounds to believe that it is the proceeds of crime.

Money Laundering is sanctioned with a fine of twenty-five thousand to one hundred thousand dollars and/or imprisonment for a term of three to five (5) years.

Sometimes attempts are made to use the banking system for the purpose of money laundering. Most of these attempts involve inducing or misleading Company personnel to accept deposits or the transfer of funds, securities and other negotiable instruments, which are the proceeds of crime, or to provide secure custody facilities for such funds or assets.

The most common form of money laundering encountered on a day-to-day basis takes the form of accumulated cash transactions deposited in the banking system or exchanged for items of value. Electronic funds transfer systems increase the vulnerability of the banking system by allowing cash deposits to be quickly moved between accounts in different names and between different jurisdictions.

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (SC 2000, c. 17) creates specific procedures and standards that, when followed, will ensure that our Company and the USA banking system in general remain free of funds. contaminated. and other assets. The Law requires us to keep a record of business transactions. This record includes, where applicable, the following:

1. The identification of all persons involved in that transaction – Review Activity Report
2. A description of that transaction sufficient to identify its purpose and method of execution.
3. Details of any account used for the transaction, including company, branch and sort code
4. The total value of that transaction.

It is the Company’s policy to verify the above information as required by law and to effectively maintain customer records for a period of not less than five years from the termination of the relationship between the Company and the customer. A financial institution commits a criminal offense if it fails to keep a record of financial transactions as required by law.

The Director of the Financial Services Unit may, upon reasonable suspicion that a money laundering offense is being committed or has been committed or is about to be committed, enter or authorize someone to enter the premises of any financial institution during the normal business hours to inspect the institution’s financial transaction record and ask any questions pertaining to such record and make notes or copies of all or part of such record. The Act also requires financial institutions to pay special attention to all complex, unusual, or large business transactions, or unusual patterns of transactions, whether or not they are completed, and to all unusual patterns of transactions and to insignificant but periodic transactions, who have no apparent financial or economic interest. lawful end.

Management should review the DDA Module Large Transaction Report and all incoming and outgoing wire transfers. It is a criminal offense for a financial institution to fail to report or falsely report such suspicion. It is also a crime to inform or “warn” the person or institution that is the object of the complaint or investigation.

TAKING INTO ACCOUNT THE REQUIREMENTS IMPOSED ON US BY THIS LAW AND OTHER RELEVANT LAWS, OUR POLICY IS:

Carry out all due diligence procedures necessary to determine the true identity of all clients or potential clients of the Company. In this way we will ensure that assets are not invested in our Company anonymously or under assumed or fictitious identities;

Provide enhanced due diligence on any customer deemed to be a “politically exposed person” (PEP); a customer who is engaged in a high-risk business, such as Internet commerce or money service business; a client engaged in business in any jurisdiction in which there is an active military conflict, suspected large-scale drug production, or terrorist activity; and/or a recurring high volume of dollar trading activity or unexpectedly large “one-time” trading transactions. In addition to the Company’s standard account opening and monitoring procedures, when a customer or transaction falls into an “enhanced due diligence” category,

Take steps to verify that all assets deposited with the Company are from legitimate sources to ensure that assets that are the proceeds of crime are not deposited with or invested in our Company;

Ensure that the Company’s personnel comply with the need to maintain the record of financial transactions required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (SC 2000, c. 17);

Ensuring that Company personnel are properly trained to maintain vigilance with respect to all unusual transactions or series of transactions. When there is a reasonable suspicion that such transaction or series of transactions constitutes money laundering, promptly report such suspicions on Form STR to SFC Financial Intelligence, as required by law;

Fully comply with the guidelines and training requirements promulgated by FinCEN Financial Intelligence in an effort to maintain Colombia’s good reputation as an ethical financial center committed to fighting economic crime;

Define and comply with the established rules of good conduct in the management of the Company;

Ensuring that the Company maintains a comprehensive client information system that establishes proper identification of individual and institutional clients, as well as a full description of business activity and source of wealth/funds;

In addition to establishing the initial KYC documentation when the customer’s account is opened, the customer will be checked against OFAC “watch lists” at least once a year and customers who fall into the “enhanced due diligence” category ” will be subject to comparison. against the OFAC list no less than quarterly. To the extent possible, Company will contract with Company software capable of automatically matching customers against OFAC lists;

The KYC documentation will also include a customer profile to enable the Company to understand the typical and expected transaction types and levels for all customers. Unexpected transactions will automatically trigger the Compliance Officer’s scrutiny by performing enhanced due diligence on the transaction;

Have the Company’s AML policies and procedures reviewed by an independent external auditor no less frequently than once a year, as well as be constantly prepared for regular scheduled and unscheduled audits by FinCEN Financial Intelligence and the FIU;

These guidelines constitute official Company policy. They will remain in force until they are modified by the Board of Directors in compliance with the legislation or subsidiary legislation dictated by the Government or the Financial Intelligence of FinCEN. However, they are subject to the following conditions:

1. Except as specifically provided by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (SC 2000, c. 17), or other relevant law, the Company’s obligation to maintain the confidentiality of its clients continues.
2. It is not the intent of these guidelines:

To incorporate

foreign currency, tax or other economic regulations in our law and therefore make them applicable to our Company (unless this is already the case under existing international treaties and USA law); Affect the current legal and fiduciary relationship that has traditionally existed between the Company and its clients (except as necessary to comply with the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (SC 2000, c. 17 ) or other laws).

1. These guidelines establish standard rules to prevent money laundering activities in the conduct of the Company’s business and are in accordance with the code of professional ethics; they are not intended to impede the efficient provision of normal services to bona fide customers.
2. These guidelines are intended to ensure the accurate determination of a client’s identity and thus enable the efficient fulfillment of the Company’s obligation to maintain an adequate record of financial transactions and to testify and provide information, as provided by USA law. All customer records must be kept for a minimum of five (5) years.
3. These guidelines are intended to ensure that the Company operates with international “best practices” to combat the spread of money laundering while respecting the legitimate confidentiality needs of our customers and the privacy laws of the United States.

PROHIBITED ACTS

Company personnel shall be prohibited from performing the following acts:

• The opening and maintenance of accounts without having ascertained the identity of (the final beneficiary of the account).
• The provision of any other service to a client without having previously observed the due prudence and diligence necessary to verify that the goods or funds come from a legitimate source.
• The Company will not provide correspondent accounts to foreign shell companies or companies that refuse to provide certification that they are not operating as a foreign shell company.
• The Company will not provide services to companies or individuals that offer internet casinos or other forms of online gambling.
• The Company will not provide information about its clients to third parties, except in the cases established in this document or by legal obligation.

ENFORCEMENT OF CARE IN THE ACCEPTANCE FUND

DETERMINATION OF THE IDENTITY OF THE BENEFICIARY

 

The Company will not open payment accounts, unless it has ascertained with the care that is reasonably possible under the circumstances, the identity of the beneficiary of the funds to be credited or invested;

 

I. SCOPE OF APPLICATION

The obligation of the staff is to verify the identity of the potential client before opening the accounts, regardless of whether said accounts are held in the name of a natural or legal person.

In the case of cash equivalent transactions (exchange, purchase and sale of precious metals, cash subscriptions of promissory notes and medium-term bonds issued by the Company, etc.), the obligation of the personnel is to verify the identity of the contracting party and verify the source of funds in any transaction in excess of US$10,000 or its equivalent).

II. IDENTIFICATION OF THE CONTRACTOR

A. Individuals

The Company verifies the identity of the contracting party who does not have a fixed address or is domiciled abroad through an official identity document (ie, passport, identity card, driving license, etc.).

B. Legal persons and companies

• The identity of legal persons will be examined by obtaining confirmation of the address indicated by the entity by mail or other equally valid means;
• Verification of the identity of said contracting party must be made by means of an extract from a commercial register or some other equally reliable document (for example, articles of incorporation, articles of association and certificate of incorporation).

All account signatories of a company must be duly accredited. In the case of an account for clubs, societies and charities, the Company will ascertain the legitimate purpose of the organization, for example, by requesting a copy of the constitution. Where there is more than one signatory to the account, the identity of at least two signatories must be initially verified and, when signatories change, care will be taken to ensure that the identity of at least two current signatories has been verified.

THIRD PARTY DETERMINATION OF THE IDENTITY OF THE BENEFICIARY

The identity of the effective beneficiary of the assets to be deposited will be determined at the time of opening the account or deposit.

All reasonable care must be exercised to identify the beneficial owner. The Company may assume that the contracting party and the usufructuary are identical. However, this can no longer be assumed if unusual circumstances are reported to the Company;

A. Legal persons and companies

If the contracting party acts on behalf of a legal entity or company, the Company must register the name of the entity, the address and the country of domicile.

IV. CASES OF DOUBT

In case of doubt, the procedure established below will be followed.

V. SURVEILLANCE

The Company must ensure that its internal control department and its auditing firm can verify the indication procedure that is carried out.

Check customer backgrounds through World Compliance and the US Treasury Department’s Office of Foreign Assets Control (OFAC) databases.

Adequate records will be kept of the name, business name, address and country of domicile of the contracting party, as well as the means used to establish identity. The documents obtained in the case of legal persons must be kept; Data relating to the identity of the final beneficiary of the natural persons who control the company must also be kept.

PROCEDURES IN CASE OF DOUBT

In case of doubt, when opening accounts or deposits, the Company will require a written statement from the client as to whether he is acting on his own account or on behalf of a third party and, in the latter case, on whose behalf. For example, doubt is justified in the following cases:

The opening of an account or deposit is requested and, at the same time, a power of attorney is granted to a person who is not recognized as sufficiently close to the account holder (for example, a foreigner), or if any other unusual person aspects arise;

The opening of an account or deposit is requested by a person whose financial situation is known to the Company. The goods delivered or to be shipped are outside the limits of the customer’s recognized financial capacity;

The opening of an account or a deposit is requested by a person domiciled abroad, who has presented himself to the Company. At the same time, a power of attorney is given to a person who is recognized as not having a sufficiently close relationship with the account holder.

The opening of an account or deposit is requested by a person domiciled abroad, who has been presented to the Company and whose financial situation is known by the Company. The goods, delivered for remission, are out of their final situation;

The opening of an account or deposit is requested by a person domiciled abroad who has not been recommended to the Company. The discussion that the Company must have with the client at the time of opening the account or deposit brings to light unusual aspects; The opening of an account or a deposit is requested by a person domiciled abroad by way of correspondence, accompanied by a signature certificate, but the potential client is not personally known by the Company.

In the event that there are serious doubts about the correctness of the client’s written statement, which cannot be eliminated by further clarification, the Company shall refuse the application for opening the account or deposit.

SAW. STR – SUSPICIOUS TRANSACTION REPORT

It is the Company’s policy to report all suspected Money Laundering transactions to the control authority that has been designated by law as the Financial Intelligence Unit. (No. 35 of 2002 Part IV, Section 20) It is further policy of the Company to file suspicious transaction reports with the FIU on all complex, unusual or large business transactions, unusual patterns of transactions (whether completed or not) and insignificant but periodic transactions. that do not have an apparent economic or lawful purpose. The Company may also consider the following indicators to determine whether a STR report should be filed:

• Does the client seem to be living beyond their means?
• Is the customer’s trading activity inconsistent with sales (ie, unusual payments from unlikely sources), industry averages, or financial rations?
• Does the client have a history of changing bookkeepers or accountants annually?
• Customer unable to locate and provide company records?
• Is the client’s business constantly in a losing position but continues to exist without a reasonable explanation for the continuing loss?
• Does the company have shareholder loans that are inconsistent with business activity?
• Does the company make large payments to subsidiaries or similarly controlled companies that are not in the normal course of business?
• Is the company repeatedly billed and does it transact with organizations located in countries that do not have adequate anti-money laundering laws?
• Does the client make statements about his involvement in criminal activities?
• Is the client continuously accompanied and monitored by third parties?
• Does the client display unusual curiosity about internal systems, controls, policies, or unusual knowledge of laws related to suspicious transaction reporting or anti-money laundering laws?
• Is the customer trying to talk an employee out of completing the paperwork required for the transaction?
• Does the customer present confusing details about a transaction or try to justify or over-explain the transaction?
• Does the customer seem reserved or nervous about the transaction?
• Has the customer’s home or business phone been disconnected shortly after opening an account?
• Does the client use aliases and/or a variety of similar but different addresses?
• Does the customer offer Company employees money, gratuities, or unusual favors for the performance of services that may appear unusual or suspicious?
• Does the client provide dubious or vague information?
• Does the customer present an apparently false identification or an identification that appears to be forged, altered, or inaccurate?
• Does the client refuse to produce personal identification documents?
• Is the customer trying to establish their identity using something other than their personal identification documents or trying to open accounts under a false name?
• Is the customer’s supporting documentation missing important details like a phone number, or are they otherwise impossible to verify?
• Do the identification documents presented look new?
• Does the customer’s transaction appear inconsistent or serve no economic purpose?
• Does significant activity suddenly appear on a dormant or dormant account?
• Does the transaction involve a country where illicit drug production or export may be prevalent or where there is no effective anti-money laundering system?
• Does the transaction involve a country known or suspected of facilitating money laundering activities? bb) Does the client offer multi-million dollar deposits from “confidential sources”?
• Does the client have transactions involving an offshore “shell” company whose name may be similar to the name of a major legitimate institution?
• Financial Institutions’ obligations and their internal reporting procedures require that adequate records be kept to compile an audit trail during money laundering investigations and prosecutions.

These records must include customer identification and related transactions. Specifically show the identity of any or all customers, as well as the details of each transaction made for each customer.

These records must be kept in a secure environment for a period of at least five years after the last relevant financial business was carried out by the institution. The objective is to enable the authorities to retrieve available relevant information without undue delay. If there is an ongoing investigation when the five-year limit is reached, the records must be kept until the authorities have closed the case.

Customer identification records must clearly show the type of identification evidence obtained from the customer and specifically show sufficient detail of the customer’s identity. A copy of this evidence must be kept as part of the client’s record.

Transaction records must be admissible in legal proceedings and must include all related information necessary to carry out the transactions. These refer to any records or information that give rise to entries in the accounts of the financial institution or in the specific account of the client. For example, duly prepared checks, wire transfers, credit/debit tickets, etc. In the case of wire transfers, all information related to senders and recipients must be included in payment messages.

When maintaining customer identification records and transaction records, keep in mind that they may be used to develop audit evidence. They must include enough information to allow authorities to locate:

• the beneficiary of an account
• the amount of money going in and out of an account
• the origin of money
• the way the money was deposited and withdrawn
• the fate of money
• the identity of the person making the transaction
• the instruction form for the transaction.

EDUCATION AND TRAINING GUIDE IN PREVENTION OF MONEY LAUNDERING ACCORDING TO LEGAL REQUIREMENTS

The purpose of this guide is twofold:

The Financial Institution must adopt the appropriate measures to keep abreast of the policies and procedures that govern the law regarding the prevention of money laundering in an effort to protect its interests.

The Financial Institution must ensure that the staff is familiar with the policies and procedures in force to prevent any possibility of money laundering. In doing so, staff should be reminded of the responsibility of their role within the organization. The guide is classified into three main categories:

• Establish an effective “Know Your Customer” policy.
• Establish a detailed record of deposits/withdrawals and transaction procedures.
• Establish a registry for handling suspicious transactions.

I. “KNOW YOUR CUSTOMER POLICY”

The Company will never establish a relationship with a client until it knows the true identity of the client. If a potential client is unwilling to provide the necessary information, the relationship should be reconsidered. If the Company has established a relationship with the client, it should be alert to any unusual business transactions. Therefore, the Company has provided formats that adequately cover all the criteria required for the establishment of said relationship. At the beginning of interviewing a client, in the event of a reluctance to provide information as set out in our banking requirements; the correct thing is to obtain the decision of the Management as a final decision. A note of caution can be discreetly placed in this client’s file for future reference.

• Identification of the account owner, preferably a passport with a photo or a driver’s license with a photo.
• Occupation of the person and type of business.
• Full address of the house and business.
• At least two references showing evidence of a satisfactory banking relationship with an acceptable financial institution for a minimum of two years, signed by a senior official to facilitate the references.
• If possible, ask how the client was referred to us.
• Check clients’ backgrounds through World Compliance and the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) databases. Tips for a joint account
• The requirements are the same as the “Indicators for a personal account” above.

Pointers to a business account

The requirements are the same as the previous ones and the following:

• If the Company is not incorporated in USA, a notarized copy of the Certificate of Incorporation, Copy of the Articles of Association and Deed of Incorporation.
• List and signatures of the Directors of the Company (these are included in forms provided by the Company.
• Two Company references on all Directors and authorized signatures.
• Evidence that the Company is in good standing for at least one year.

II. DETAILED RECORD OF DEPOSITS/WITHDRAWALS AND TRANSACTION PROCEDURES

A client file will be established immediately in which all personal or company data will be stored. Along with this, the copy of the entire transaction, including the copies of the entries, must be kept for at least five years. Regarding deposited checks, a copy of this item will be deposited for remission. No funds will be released. Funds will be “frozen” for the appropriate period until liquidation as stipulated in the Company manual. For wire transfers, a copy of the incoming/outgoing telex will be kept on file. Information such as company source, sender name, reference number, date of transaction, and dollar amount should be recorded. At a minimum, we should have information on hand about:

• The origin of the funds.
• How the funds were deposited or withdrawn.
• The identity of the person who made the transaction and their signature on the record.
• Your signature on the record.
• The destination of the funds. The form of instruction or authority.

Clients who enter with large amounts of dollars must present proof of declaration of funds entered into the country either at the International Airport, the borders or at the FinCEN Financial Intelligence. The Company must keep this form duly stamped by a Government Agency to protect its interests. This form will show or should show where the source of the funds originated. Our Source of Funds form must be completed. In addition, the following lists of routinely produced internal reports are helpful:

• Deposit/Withdrawal Large Transaction Report
• comet suspect report
• Records of incoming and outgoing bank transfers
• Monetary record for items $3,000 and over.

THIRD SUSPICIOUS TRANSACTIONS

Although it is difficult to define what a suspicious transaction is, a simple clue would be, when in doubt, to consult. Be on the lookout for anything out of the ordinary on a know-your-customer basis. Therefore, it is recommended that staff familiarize themselves with customer activities to recognize when a transaction is unusual. However, please note that an unusual transaction may not necessarily be a suspicious transaction. Some helpful tips are:

• Beware of activity that is not consistent with the client’s business.
• Beware of attempts to circumvent reporting or record-keeping requirements.
• Be aware of funds transfer activities.
• Beware of a client who provides false information.

Again, any of the above may not be illegal activity; it just means that the transaction may require closer scrutiny. However, as a precautionary measure, should any situation arise, it must be duly documented or authorized by senior management for reporting purposes. The Company’s goal is to provide refresher training at regular intervals in an effort to:

• Detect suspicious activity in a timely manner.
• Comply with all regulatory laws.
• Promote safe and sound practices.
• Minimize the risk that the Company is used for illicit activities.
• Protect the Company’s reputation.

Staff sessions to discuss these issues for feedback should be encouraged along with additional training support provided by FinCEN Financial Intelligence.

IV. MONEY LAUNDERING – STAGES OF THE PROCESS

Placement

This is the first stage in the wash cycle. Money laundering is a “cash intensive” business, generating large amounts of cash from illegal activities (for example: street drug sales where payment is made in cash in small denominations). Monies placed in the financial system or the retail economy or are smuggled out of the country. The objectives of the launderer are to remove the cash from the place of acquisition to avoid detection by the authorities and then transform it into other forms of assets (for example: traveler’s checks, money orders, etc.).

layers

In the course of layering, there is the first attempt to hide or disguise the source of ownership of funds by creating complex layers of financial transactions designed to disguise the audit trail and provide anonymity. The purpose of layering is to dissociate illegal money from the source of the crime by deliberately creating a complex web of financial transactions intended to hide any audit trail, as well as the source and ownership of the funds.

Layers are typically created by moving money in and out of the offshore company accounts of shell companies with bearer shares via electronic funds transfers. Given that there are more than 500,000 wire transfers, representing more than $1 trillion, circulating in the world daily, most of which are legitimate, there is not enough information disclosed on any transfer to know how clean or dirty the money is, thus providing an excellent way for launderers to move their dirty money. Other forms used by launderers are complex transactions with stock, commodity and futures brokers. Given the large volume of daily transactions and the high degree of anonymity available,

Integration

The final stage in the process. It is this stage in which money is integrated into the legitimate economic and financial system and is assimilated with all other assets in the system. The launderer achieves the integration of the “cleaned” money into the economy by making it appear that it has been legally earned. At this stage, it is extremely difficult to distinguish legal from illegal wealth. Popular methods for money launderers at this stage of the game are:

• The establishment of corporations in countries where the right to secrecy is guaranteed. Loans can then be made with the laundered money in the course of future legal transactions. Additionally, to increase their earnings, they will also claim tax relief on loan repayments and interest will be charged on the loan.
• Sending false export-import invoices overvaluing goods allows the launderer to move money from one company and country to another, using the invoices to verify the origin of the money placed in financial institutions.
• A simpler method is to transfer the money via wire transfer to a legitimate company from a company owned by launderers, as “off-the-shelf” companies are easily purchased in many tax havens.

V. MONEY LAUNDERING – MONEY LAUNDERING METHODS

How the basic steps mentioned in the Process Steps are used depends on the available laundering mechanism and the requirements of criminal organizations. The following table provides some typical examples. Placement stage Layering stage Integration stage Cash paid to the company (sometimes with the complicity of staff or mixed with profits from legitimate businesses). Overseas wire transfers (often using shell companies or funds disguised as proceeds of legitimate businesses). Fake loan payments or falsified invoices used as cover for money laundering. Exported cash Cash deposited in the banking system abroad. The complex network of transfers (both domestic and international) makes it virtually impossible to trace the original source of the funds. Resale of goods/assets. Cash used to purchase high-value assets, property, or business assets.

These are a small selection of the ways people clean their “dirty money”. These schemes are still being used on unsuspecting businesses, as although the authorities are aware of them, not many people are aware of, or even have access to, this type of information.

ESTABLISH AN EFFECTIVE “KNOW YOUR CUSTOMER” POLICY

Strong “Know Your Customer” policies are a company’s most effective weapon against the inadvertent use of money to launder money. Knowing your customers, including depositors and other users of the Company’s services, requiring proper identification and being alert to unusual or suspicious transactions can help deter and detect money laundering schemes.

A “KNOW YOUR CUSTOMER” POLICY ADAPTED TO THE OPERATIONS OF THE COMPANY:

Helps detect suspicious activity in a timely manner; Promotes compliance with all banking laws; Promote safe and sound banking practices; Minimize the risk of the Company being used for illegal activities; Reduces the risk of government seizure and confiscation of a client’s loan collateral when the client is involved in criminal activity, and protects the Company’s reputation.

In general, a business should never establish a relationship with a customer until it knows the true identity of the customer. If a potential client is unwilling to provide the necessary information, the relationship should be reconsidered. If the Company has established a relationship with the client, it should be alert to any unusual business transactions. What we should look for

The following situations may indicate money laundering. These lists are not all-inclusive, but they can help us recognize ways launderers can address them.

• Beware of activity that is not consistent with the client’s business
• Watch out for unusual features or activities
• Beware of attempts to circumvent reporting or record-keeping requirements
• Beware of Certain Funds Transfer Activities
• Beware of a customer who provides insufficient or suspicious information
• Beware of certain company employees, and
• Watch out for changes in company transactions.

Transactions such as those mentioned above may deserve attention. The fact that a transaction appears on the list does not mean that it involves illegal activity. It just means that the transaction requires close scrutiny. Many of these activities are suspicious only because they are inconsistent with normal customer behavior. Upon further examination, it can be determined that such transaction is a legitimate business activity. Similarly, other transactions mentioned in the note may be suspicious if they are inconsistent with the normal activity of a particular customer.

Two important aspects of knowing your customer are:

1. Being satisfied that a potential customer is who they say they are and is the end customer; Y
2. Ensuring that sufficient information is obtained about the nature of the business the client hopes to undertake, as well as any expected or predictable patterns of transactions. This information is updated as appropriate and as opportunities arise.

1. As part of the due diligence process, IRIS CASH LLC.:

• Use reasonable measures to adequately verify and document the identity of the customer or account holder at the beginning1 of a business relationship. This process should include, where appropriate:
  1. Take reasonable steps to understand the client’s ownership and control structure;
  2. Obtain information about the purpose and intended nature of the business relationship, the source of funds, and the source of wealth, where applicable; Y
  3. Discontinue the transaction, if the information in the client documentation is not available at the beginning of the relationship.
• Employ enhanced due diligence procedures for high-risk customers or transactions or business relationships, such as private banking operations, non-resident customers, trust agreements, companies that have nominee shareholders, or customers for whom the Company has reason to believe another company is treating them. denying banking services;
• Monitor account activity throughout the life of the business relationship; Y
• Review existing records if there is a material change in the way the account is operated or if there are questions about previously obtained customer identification data.

2. In conducting the due diligence process, IRIS CASH LLC.:

• Whenever possible, require prospective clients to be interviewed in person. Exceptions to this are described in the sections on Non-Face-to-Face Customers and Introduced Businesses;
• Use documents, data or official information or from another reliable source to verify the identity of the final beneficiary before opening the account or establishing the business relationship (whether permanent or occasional, whether a natural or legal person). Identification documents that do not bear a photograph or signature and that are easy to obtain (for example, birth certificate and driver’s license) are not acceptable as the sole means of identification. Verification may involve the use of external electronic databases.
• In cases where original documents are not available, only accept copies certified by an authorized person (see Appendix 6). Approved individuals must print their name clearly, state their title or capacity along with a contact address and phone number;
• If the documents are unfamiliar to you, take additional steps to verify that they are authentic, for example by contacting the relevant authorities.

3. For the purposes of these Guidelines, IRIS CASH LLC. will seek to identify the client and all those who exercise control over the account/transaction. A client includes:

• A person or entity that maintains an account with IRIS CASH LLC.
• A person or entity in whose name an account is held, i.e. beneficial owner;
• The beneficiaries of transactions carried out by professional intermediaries such as lawyers, accountants, notaries, business introducers or any other provider of professional services; either
• Any person or entity involved in a financial transaction that may pose a significant risk to IRIS CASH LLC., including persons establishing business relationships, purporting to act on behalf of a client, or conducting transactions such as: Opening deposit accounts; Enter into fiduciary transactions; Rental of safes; Request secure custody facilities; and Occasional Transactions exceeding thresholds as discussed below or linked transactions under this benchmark, and all occasional wire transfers.

4. Generally, IRIS CASH LLC. You should not accept funds from prospective clients unless the necessary verification has been completed. In exceptional circumstances, verification of the identity of the customer and the beneficial owner may be carried out after the establishment of the business relationship, provided that:

• It is done as soon as reasonably possible;
• It would be critical not to disrupt the normal course of business (for example, non-face-to-face trade and securities transactions);
• Money laundering risks are effectively managed. If IRIS CASH LLC. determines this to be an unacceptable risk, we will retain control of the funds received until verification requirements are met. If requirements are not met and IRIS CASH LLC. determines that the circumstances give rise to suspicion, it must make a report to the FIU.

5. Where a customer is permitted to use the business relationship prior to verification, financial institutions must adopt risk management procedures under which this may occur. These procedures must include a set of measures on the limitation of the number, types and/or amount of transactions that can be carried out and the monitoring of large or complex transactions outside the expected norm for the type of relationship.

6. When the financial institution is unable to successfully complete the CDD requirements, it should not open the account, enter into business relationships, or conduct the transaction. You should also consider making a suspicious transaction report.

7. When there is a suspicion that an asset is derived from criminal activity, or linked or related to, or will be used to finance terrorism or a transaction related to money laundering or the financing of terrorism, IRIS CASH LLC. You should be aware of the possibility of alerting a customer when performing due diligence. IRIS CASH LLC. a business decision must be made as to whether to open the account or execute the transaction, as the case may be, but a STR must be submitted to the FIU.

IMPROVEMENT PROCESS AGAINST MONEY LAUNDERING

The Compliance Officer of IRIS CASH LLC. (IRIS CASH) under the supervision of your COO must understand the relationship between the persons responsible for monitoring AML and the management of the Company. The Compliance Officer of IRIS CASH LLC. o Your COO must ensure that the persons responsible for monitoring AML do not have sufficient authority (real and perceived) and influence in IRIS CASH LLC. (IRIS CASH).

Perform management AML risk assessment of all major lines of business, products and services.

The Compliance Officer, under the supervision of your COO, will conduct an annual evaluation and it will be managed by our Compliance Officer. IRIS CASH LLC.H will consider risk as a product of volume, regulation, staff turnover, regulatory approach. IRIS CASH LLC. will also look at more than just cash transactions, we will also look at each of the Company’s lines of business to determine how they could be abused by money launderers.

Please provide a copy of the most recent AML policy and procedures approved by the Board.

The Compliance Officer, under the supervision of your COO, will maintain records of when IRIS CASH LLC’s policy and procedures were last reviewed by the Board of Directors. The Board of Directors supports the AML efforts of IRIS CASH LLC and is committed to providing the personnel and other assets necessary to implement this policy. IRIS CASH LLC will ensure that the AML policy reflects the current regulatory environment and is reviewed annually.

Properly maintain the most recent Know Your Customer (KYC) Policy approved by the Board.

The Compliance Officer, under the supervision of your COO, will update any future changes and ensure that our staff follows the policy, providing semi-annual training. IRIS CASH LLC. will engage SFC financial intelligence for any current updates regarding AML and will make any necessary updates to the IRIS CASH LLC Policies and Procedures Manual.

Properly maintain policy and procedures related to Suspicious Activity Report (SAR) reporting and monitoring requirements.

The Compliance Officer, under the supervision of your COO, will review how IRIS CASH LLC handles SAR responsibilities. Ensure that all departments understand their roles in submitting suspicions for centralized consideration and filing. Share the lessons learned in the documents, particularly those related to the reporting of illegal or suspicious actions that may affect the Company.

Review the results of the most recent independent audit regarding compliance, including management responses.

The Compliance Officer, under the supervision of your COO, will review the most recent audit to determine whether, in our opinion, our Company is doing a thorough job.

IRIS CASH LLC. You will properly maintain AML records of the training program with dates, attendees, and topics.

Records will be maintained by the Compliance Officer or COO. Meetings where these topics are discussed will be documented as part of these records. Secure and determine if there are employees who require initial or additional training.

Training files (for example, materials used for training).

The Compliance Officer, under the supervision of your COO, will include information that has been distributed to inform Company employees of AML requirements.

File of Suspicious Activity Reports (SAR)

The Compliance Officer, under the supervision of your COO, will maintain on file any follow-up SARs and all reports or other documents used in the company’s investigation of the activity described in the reports. In addition, IRIS CASH LLC must also maintain a file of any activity that the Company investigated and for which the Company determined not to file a SAR, including the basis for that decision.

Records or other method reflecting incoming and outgoing bank transfers.

The Compliance Officer, under the supervision of your COO, will review and determine whether such patterns of large wire transfers followed by wire transfers from the same customer are justified based on the business or customer involved. Also discuss the types and volume of wire transfer activities conducted by the Company. Please include accepted payment methods for such transfers as well as acceptable senders (for example, account holders vs. non-account holders).