Anti-Money Laundering (AML) Policy

Introduction

Zeroscrow INC is committed to preventing money laundering and terrorist financing through the implementation of comprehensive Anti-Money Laundering (AML) policies. We aim to comply with all applicable local and international laws, regulations, and guidelines. This policy outlines the procedures and controls we have put in place to protect our services and customers from being misused for illegal activities.

Objective

The primary objective of this AML Policy is to prevent money laundering and other financial crimes, protect the company’s reputation, and ensure that we comply with legal obligations. We are committed to safeguarding our business from financial crime risks, including the prevention of:

  • Money laundering
  • Terrorist financing
  • Fraudulent transactions
  • The misuse of our platform for illegal activities

AML Procedures

To ensure compliance with AML regulations, Zeroscrow INC has established the following procedures:

1. **Customer Identification Program (CIP):** We will identify and verify the identity of our clients at the time of account creation and before any transactions are processed. This includes obtaining and verifying information such as name, address, date of birth, and government-issued identification.

2. **Suspicious Activity Reporting (SAR):** Our compliance team is responsible for monitoring transactions for suspicious activity. If any transaction is deemed suspicious or potentially linked to money laundering, we will file a Suspicious Activity Report (SAR) with the relevant authorities.

3. **Ongoing Monitoring:** We will continuously monitor our customers' transactions and activities for signs of money laundering, such as unusual patterns or high-risk transactions. This monitoring will be conducted in real-time to identify and mitigate risks.

4. **Recordkeeping:** All customer information, transaction records, and supporting documentation will be securely stored for a minimum of five years, in compliance with legal requirements.

5. **AML Training:** We provide ongoing training to our employees, partners, and contractors regarding the importance of AML compliance, the identification of suspicious activities, and the proper steps to take when unusual activity is identified.

Risk Assessment

Zeroscrow INC conducts a risk-based approach to its AML policy. This involves categorizing clients, transactions, and geographic regions based on risk levels. We assess each client’s risk profile and apply appropriate controls depending on the level of risk identified.

Compliance Officer

Zeroscrow INC has appointed a dedicated Compliance Officer responsible for overseeing the implementation and enforcement of the AML Policy. The Compliance Officer will ensure that all employees and stakeholders comply with the AML regulations and report any suspicious activity.