Anti-Money Laundering Policy and Counter-Terrorist Financing (CTF) Compliance

Anti-Money Laundering Policy and Counter-Terrorist Financing (CTF) Compliance

  1. Introduction

Metaco Intelligence Corporation is committed to the highest anti-money laundering (AML) and counter-terrorist financing (CTF) compliance standards. We understand the importance of preventing our business from being used to launder money or finance terrorist activities.

This policy sets out our commitment to AML and CTF compliance and the procedures that we have in place to meet our obligations.

  1. Definitions

Money laundering: The process of concealing the origins of illegally obtained money.

Terrorist financing: The process of providing financial support to terrorist organizations.

Customer Due Diligence (CDD): The process of verifying the identity of our customers and understanding their business.

Suspicious Transaction Report (STR): A report that we must submit to the authorities if we suspect that a transaction may be related to money laundering or terrorist financing.

  1. AML Compliance Officer

In case of any suspicious activity or If you have any concerns about our AML and CTF compliance, reach out at compliance@zoth.io

  1. Risk Assessment

Conduct a risk assessment to identify and understand money laundering risks associated with the organization's activities, products, and services.

Develop a risk-based approach to allocate resources effectively

  1. AML and CTF Obligations

We are subject to a number of AML and CTF obligations, including:

The Singapore Anti-Money Laundering and Counter-Terrorism Financing Act 2007 (AMLA).

The Financial Action Task Force (FATF) Recommendations.

  1. Customer Due Diligence (CDD)

Establish procedures for identifying and verifying the identity of customers.

Understanding the customer's business

Assessing the customer's risk of money laundering or terrorist financing

Define enhanced due diligence measures for higher-risk customers.

Describe ongoing monitoring of customer accounts for suspicious activities.

  1. Know Your Customer (KYC)

Define the information required to know the customer's background, purpose of the relationship, and the source of funds.

Verify the beneficial ownership of legal entities and high net worth individuals.

  1. Suspicious Activity & Transaction Reporting (SATR)

Establish procedures for employees to report suspicious activities internally.

Define the process for filing Suspicious Activity Reports with the appropriate authorities.

  1. Transaction Monitoring

Implement a system to monitor transactions and detect unusual or suspicious patterns.

Describe the process for investigating flagged transactions and resolving potential AML concerns.

  1. AML Training

Provide regular AML training for employees, ensuring they are aware of AML regulations and their role in compliance.

Document training sessions and maintain records of attendance.

Zoth will enforce its AML/CFT policy. Employees who violate the policy will be subject to disciplinary action, up to and including termination of employment.

Policy Acknowledgment: Require employees to acknowledge their understanding and compliance with the AML policy.

  1. Record Keeping

Define record-keeping requirements for customer information, transactions, and AML compliance-related documentation.

Specify the retention period for records.

  1. Sanction Compliance

Establish procedures for complying with international sanctions programs.

Regularly screen customers and transactions against relevant sanctions lists.

  1. Third-Party Due Diligence

Zoth will conduct regular audits of the AML/CFT program. The audits will be conducted by an independent auditor. The audits will assess the effectiveness of the AML/CFT program and identify any areas for improvement.

  1. Internal Controls and Reporting

Develop internal controls to ensure compliance with the AML policy.

Establish mechanisms for regular reporting to senior management and the board of Directors.

  1. Monitoring and Review

Our AML and CTF compliance program is subject to regular monitoring and review. We will review our program on a regular basis to ensure that it is effective in meeting our obligations.

  1. Non-Retaliation

Assure employees that they will not face retaliation for reporting suspicious activities or potential AML violations.

  1. Penalties for Non-Compliance

Outline the consequences of non-compliance with the AML policy, including disciplinary actions and potential legal consequences.

  1. Disclaimer

This policy is not a contract and does not create any legally binding obligations between Zoth and its employees and its users. Zoth does not guarantee that its AML/CFT program will prevent all money laundering or terrorist financing activity. Employees are responsible for complying with the policy and for reporting any suspected violations to their supervisor.

  1. Conclusion

We are committed to the highest standards of AML and CTF compliance. This policy provides a clear framework for our employees to follow, and that will help us to meet our obligations.

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