Anti-Money Laundering (AML) Policy

1. Introduction

Lessee & Lessor ("we," "our," or "us") is committed to preventing money laundering and terrorist financing activities. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to ensure compliance with applicable laws and regulations.

We operate as a property rental platform that facilitates financial transactions between lessors and lessees. As such, we have implemented comprehensive AML measures to detect, prevent, and report suspicious activities.

2. Legal Framework

Our AML program is designed to comply with:

• Bank Secrecy Act (BSA) and related regulations
• USA PATRIOT Act
• Financial Action Task Force (FATF) recommendations
• Local and international AML/CFT regulations
• Industry best practices and standards

3. Customer Due Diligence (CDD)

Identity Verification

Before allowing users to conduct transactions, we verify their identity through:

• Government-issued photo identification
• Proof of address documentation
• Biometric verification where available
• Document authentication and validation
• Database checks against sanctions lists

Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to:

• High-value transactions exceeding predefined thresholds
• Customers from high-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Business entities with complex ownership structures
• Customers with unusual transaction patterns

4. Transaction Monitoring

We employ automated and manual monitoring systems to detect suspicious activities, including:

• Unusual transaction patterns or frequencies
• Transactions inconsistent with customer profiles
• Large cash transactions or structuring
• Transactions involving high-risk countries
• Rapid movement of funds without apparent business purpose
• Use of multiple accounts or shell companies

5. Suspicious Activity Reporting

When suspicious activities are identified, we:

• Conduct immediate investigation and documentation
• File Suspicious Activity Reports (SARs) with appropriate authorities
• Implement additional monitoring and controls
• Consider account restrictions or termination if necessary
• Maintain confidentiality of reporting activities

6. Record Keeping

We maintain comprehensive records for AML compliance, including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• Suspicious activity reports and investigations
• Training records for staff
• Policy updates and revisions

Records are maintained for a minimum of five years from the date of account closure or last transaction, as required by applicable regulations.

7. Staff Training and Awareness

All employees receive regular AML training covering:

• Recognition of suspicious activities and red flags
• Customer due diligence procedures
• Reporting requirements and procedures
• Regulatory updates and changes
• Consequences of non-compliance

8. Risk Assessment

We conduct regular risk assessments to identify and evaluate:

• Customer risk profiles and categories
• Geographic risk factors
• Product and service risk levels
• Delivery channel risks
• Emerging threats and trends

9. Sanctions Screening

We screen all customers and transactions against:

• OFAC (Office of Foreign Assets Control) sanctions lists
• UN Security Council sanctions
• EU sanctions lists
• Other relevant international sanctions
• Domestic watch lists and PEP databases

10. Compliance Officer

We have designated a Compliance Officer responsible for:

• Overseeing the AML program
• Ensuring regulatory compliance
• Training and education of staff
• Liaising with regulatory authorities
• Regular program review and updates

11. Third-Party Relationships

We conduct due diligence on third-party service providers, including:

• Payment processors and financial institutions
• Identity verification service providers
• Technology vendors and contractors
• Legal and compliance advisors

12. Reporting and Escalation

All employees are required to:

• Report suspicious activities immediately
• Follow established escalation procedures
• Maintain confidentiality of investigations
• Cooperate with law enforcement when required
• Document all relevant information

13. Program Review and Updates

Our AML program is subject to regular review and updates to:

• Ensure continued effectiveness
• Address new regulatory requirements
• Incorporate lessons learned from investigations
• Adapt to emerging threats and risks
• Improve operational efficiency

14. Enforcement and Penalties

Violations of this AML Policy may result in:

• Disciplinary action up to and including termination
• Legal and regulatory penalties
• Civil and criminal liability
• Reputational damage
• Loss of business licenses or authorizations

15. Contact Information

For questions or concerns regarding this AML Policy, please contact our Compliance Officer: