Anti-Money Laundering (AML) Policy

1. Introduction

PickStart is committed to preventing money laundering and terrorist financing activities on our platform. This Anti-Money Laundering (AML) Policy outlines our procedures and controls designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

We implement comprehensive AML compliance measures to protect our platform, our users, and the financial system from abuse by money launderers and terrorist financiers.

2. Legal Framework

Our AML compliance program is designed to comply with applicable anti-money laundering and counter-terrorist financing laws and regulations, including but not limited to:

• Bank Secrecy Act (BSA) and related regulations
• USA PATRIOT Act requirements
• Financial Action Task Force (FATF) recommendations
• Applicable local and international AML/CFT regulations

3. Customer Due Diligence (CDD)

3.1 Identity Verification

We verify the identity of all users who create accounts on our platform. Our identity verification process includes:

• Collection of full name, date of birth, and contact information
• Email verification through secure authentication methods
• Location verification to ensure compliance with jurisdictional requirements
• Additional verification for high-risk transactions or activities

3.2 Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for higher-risk customers, transactions, or situations, including:

• Large or unusual transactions
• Users from high-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Unusual patterns of activity
• Complex transaction structures

3.3 Ongoing Monitoring

We continuously monitor customer accounts and transactions to identify any unusual or suspicious patterns of activity that may indicate money laundering or terrorist financing.

4. Suspicious Activity Detection

We monitor for and investigate the following types of suspicious activities:

• Multiple accounts opened with similar or identical information
• Unusual transaction patterns or volumes
• Rapid movement of funds between accounts
• Transactions inconsistent with stated business or personal purposes
• Structured transactions designed to avoid reporting thresholds
• Use of accounts by persons other than the account holder
• Transactions involving high-risk jurisdictions
• Unusual payment methods or sources of funds
• Attempts to evade identity verification or screening

5. Reporting Requirements

In accordance with applicable laws and regulations, we:

• File Suspicious Activity Reports (SARs) with appropriate regulatory authorities when we identify suspicious transactions or activities
• Report large cash transactions as required by applicable regulations
• Cooperate with law enforcement and regulatory agencies in investigations
• Maintain confidentiality of SAR filings as required by law

We are prohibited from disclosing to customers that a SAR has been filed regarding their transactions or accounts.

6. Sanctions Screening

We screen all customers against international sanctions lists and watchlists, including:

• Office of Foreign Assets Control (OFAC) sanctions lists
• United Nations Security Council sanctions lists
• European Union sanctions lists
• Other applicable national and international sanctions regimes

We do not conduct business with individuals or entities on sanctions lists and will immediately freeze or close any accounts identified as matching sanctions targets.

7. Record Keeping

We maintain comprehensive records of all customer transactions, identity verification documents, and AML-related activities in accordance with applicable record-keeping requirements. These records include:

• Customer identification and verification records
• Transaction records and documentation
• Suspicious activity reports and related documentation
• Compliance training records
• AML program documentation and reviews

Records are maintained for the period required by applicable laws and regulations, typically a minimum of five to seven years.

8. Employee Training

All employees who handle customer transactions or interact with users receive regular AML training, including:

• Recognition of suspicious activity patterns
• Customer due diligence procedures
• Reporting requirements and procedures
• Sanctions compliance
• Legal and regulatory updates

9. Cooperation with Authorities

We fully cooperate with law enforcement, regulatory authorities, and financial intelligence units in their efforts to combat money laundering and terrorist financing. This includes providing information and documentation as required by law, court orders, or regulatory requests, while maintaining appropriate confidentiality safeguards.

10. Prohibited Activities

Users are strictly prohibited from using our platform for any illegal activities, including but not limited to:

• Money laundering
• Terrorist financing
• Fraud or financial crimes
• Evasion of taxes or other financial obligations
• Any activity that violates applicable laws or regulations

Violations of this policy may result in immediate account closure, reporting to relevant authorities, and legal action.

11. Compliance Review

Our AML compliance program is subject to regular independent review and testing to ensure its effectiveness and compliance with applicable regulations. We continuously update our policies and procedures to reflect changes in regulations, industry best practices, and emerging risks.

12. User Cooperation

Users must cooperate with our AML procedures, including:

• Providing accurate and complete information during registration and verification
• Responding promptly to requests for additional information or documentation
• Reporting any suspected fraudulent or suspicious activity
• Complying with all applicable laws and regulations

13. Contact Information

If you have questions about our AML Policy or need to report suspicious activity, please contact us at info@pickstart.com.