Anti-Money Laundering Policy

1. Policy Statement

MiarichPay is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations. We have zero tolerance for money laundering and terrorist financing activities.

This policy applies to all employees, contractors, business partners, and customers of MiarichPay and covers all products and services we provide.

2. Regulatory Framework

Our AML program complies with all applicable laws and regulations, including:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• FinCEN regulations
• OFAC sanctions programs
• State money transmitter laws
• International AML standards (FATF recommendations)

We regularly update our procedures to reflect changes in applicable laws and regulatory guidance.

3. Customer Due Diligence (CDD)

Identity Verification

We verify the identity of all customers before establishing a business relationship. This includes:

• Government-issued photo identification
• Social Security Number or Tax ID verification
• Address confirmation through utility bills or bank statements
• Business registration documents for corporate accounts

Enhanced Due Diligence (EDD)

For high-risk customers, we implement enhanced due diligence measures:

• Source of funds verification
• Business purpose and nature documentation
• Ongoing monitoring of transaction patterns
• Periodic review and update of customer information

4. Politically Exposed Persons (PEPs)

We maintain enhanced screening procedures for Politically Exposed Persons, including:

• Current and former government officials
• Senior political party officials
• High-ranking military officials
• Senior executives of state-owned enterprises
• Family members and close associates of PEPs

PEP accounts require additional approval and ongoing monitoring with enhanced scrutiny of transaction patterns and sources of funds.

5. Sanctions Screening

We screen all customers and transactions against relevant sanctions lists, including:

• OFAC Specially Designated Nationals (SDN) list
• OFAC sectoral sanctions lists
• UN Security Council sanctions lists
• EU sanctions lists
• Other applicable government sanctions programs

6. Transaction Monitoring

Automated Monitoring

Our automated transaction monitoring system flags potentially suspicious activities based on:

• Unusual transaction amounts or patterns
• Rapid movement of funds
• Transactions inconsistent with customer profile
• Geographic risk factors
• Velocity and frequency of transactions

Manual Review

Trained compliance officers review flagged transactions to determine if they warrant further investigation or reporting to authorities.

Record Keeping

We maintain comprehensive records of all transactions and customer information as required by applicable regulations, typically for a minimum of five years.

7. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with FinCEN when we detect transactions that:

• Involve or aggregate $5,000 or more and we suspect money laundering
• Appear designed to evade reporting requirements
• Lack apparent lawful purpose
• Involve known or suspected criminal activity

8. Currency Transaction Reporting

We file Currency Transaction Reports (CTRs) for:

• Cash transactions exceeding $10,000 in a single day
• Multiple transactions that aggregate to over $10,000
• Transactions structured to avoid reporting thresholds

CTRs are filed within 15 days of the transaction date as required by federal regulations.

9. High-Risk Jurisdictions

We apply enhanced scrutiny to transactions involving jurisdictions identified as high-risk by:

• Financial Action Task Force (FATF)
• U.S. Department of State
• Other relevant international organizations

Transactions to or from these jurisdictions may require additional documentation and approval.

10. Training and Awareness

Employee Training

All employees receive comprehensive AML training covering:

• AML laws and regulations
• Company policies and procedures
• Red flags and suspicious activity indicators
• Reporting procedures and responsibilities

Ongoing Education

Regular updates and refresher training ensure employees stay current with evolving threats and regulatory requirements.

11. Third-Party Risk Management

We conduct due diligence on all third-party service providers and business partners to ensure they:

• Maintain adequate AML controls
• Comply with applicable regulations
• Have appropriate screening procedures
• Provide necessary transaction information

Contracts with third parties include specific AML compliance requirements and right to audit provisions.

12. Independent Testing and Audit

Our AML program undergoes regular independent testing to ensure effectiveness and compliance. This includes:

• Annual independent AML audits
• Transaction testing and sampling
• Policy and procedure reviews
• System testing and validation

Audit findings are addressed promptly with appropriate corrective actions.

13. Reporting Obligations

Customers and employees have a duty to report suspected money laundering or terrorist financing activities. Reports should be made immediately to:

14. Penalties and Enforcement

Violations of this AML policy may result in:

• Immediate account suspension or termination
• Reporting to law enforcement agencies
• Civil and criminal penalties
• Forfeiture of funds
• Permanent exclusion from our services

15. Policy Updates

This policy is reviewed and updated regularly to reflect changes in laws, regulations, and industry best practices. All stakeholders will be notified of material changes.

For questions about this policy or to report suspicious activity, please contact our AML Compliance team using the information provided above.