Building Trust in a Trustless Ecosystem: unFederalReserve’s Anti-Money Laundering Policy

Residual Token, Inc.

Bank Secrecy Act (“BSA”)

Anti-Money Laundering (“AML”) Policy:

Contents

I. COMPANY POLICY

  1. Includes a system of internal controls to assure ongoing compliance
  2. Designates an individual to assure day-to-day compliance
  3. Requires training for unFederalReserve stakeholders with Compliance exposure
  4. Requires annual internal and/or external Independent Testing for compliance
  5. Implements a Know Your Customer (“KYC”) Program inclusive of appropriate risk-based procedures for conducting ongoing customer due diligence, and
  6. Implements a Customer Identification Program (“CIP”).

II: BSA/AML COMPLIANCE SPECIALIST DESIGNATION AND DUTIES

III. GIVING AML INFORMATION TO FEDERAL LAW ENFORCEMENT

  1. FinCEN Requests Under USA PATRIOT Act Section 314(a)

IV. KNOW YOUR CUSTOMER (“KYC”)

  1. Use of a Vendor for KYC process
  • For an individual, an unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport; and
  • For a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument.

V. CUSTOMER DUE DILIGENCE RULE

  1. Identification and Verification of Beneficial Owners
  • The type of mer;
  • The account or service being offered;
  • The customer’s income;
  • The customer’s net worth;
  • The customer’s domicile;
  • The customer’s principal occupation or business; and
  • In the case of existing customers, the customer’s history of activity.

VI. TRANSACTION MONITORING

  1. FinCEN’S issuance of Special Measures

VII. SUSPICIOUS TRANSACTIONS AND BSA REPORTING

  1. Filing a SAR
  1. The transaction involves funds derived from illegal activity,
  2. Is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade federal law or regulation or to avoid any transaction reporting requirement under federal law or regulation;
  3. The transaction is designed, whether through structuring or otherwise, to evade any requirements of the BSA regulations;
  4. The transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, unFederalReserve knows of no reasonable explanation for the transaction; or
  5. The transaction involves the use of unFederalReserve to facilitate criminal activity.

VII. RECORDKEEPING AND RETENTION

  1. Responsibility for Required AML Records and SAR Filing

IX. TRAINING PROGRAMS

X. TEST OF AML PROGRAM

  • Customer due diligence
  • Transaction monitoring
  • Required reporting and recordkeeping,
  • Training, and
  • The BSA/AML Compliance Specialist functions.

XI. CONFIDENTIAL REPORTING OF AML NON-COMPLIANCE

XII. SENIOR MANAGEMENT APPROVAL

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‘Credit vs Cash’ spot market fintech using blockchain protocols. Great liquidity access. Instantaneous settlement. $ersdl #DeFI #middlemarketdefi #uniswap

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