Commertize, Inc. ("Commertize," "we," "us," or "our") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This AML Policy outlines our commitment to preventing the use of our platform for money laundering, terrorist financing, or other financial crimes.
1. Policy Statement
Commertize maintains a zero-tolerance policy towards money laundering and terrorist financing. We are committed to complying with all applicable AML laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, Financial Crimes Enforcement Network (FinCEN) regulations, and other relevant federal and state laws. Our platform is designed to detect, prevent, and report suspicious activities to the appropriate authorities.
2. Regulatory Framework
Our AML program is designed to comply with:
- Bank Secrecy Act (BSA) of 1970
- USA PATRIOT Act of 2001
- FinCEN Customer Due Diligence (CDD) Rule
- Office of Foreign Assets Control (OFAC) Sanctions Programs
- Securities and Exchange Commission (SEC) regulations
- Financial Action Task Force (FATF) Recommendations
3. AML Program Components
Our AML compliance program includes the following key components:
Designation of AML Compliance Officer
A qualified individual responsible for overseeing the AML program, ensuring compliance, and serving as the primary point of contact for regulatory inquiries.
Written Policies and Procedures
Comprehensive internal policies and procedures designed to detect and prevent money laundering and terrorist financing activities.
Customer Due Diligence (CDD)
Risk-based procedures for verifying customer identity, understanding the nature of customer relationships, and conducting ongoing monitoring.
Employee Training
Regular training programs for all employees on AML requirements, red flags, and reporting obligations.
Independent Audit
Periodic independent testing of our AML program to ensure its effectiveness and identify areas for improvement.
4. Customer Identification Program (CIP)
Before establishing a business relationship, we verify the identity of all customers through our Customer Identification Program, which includes:
- Collection of identifying information (name, date of birth, address, identification number)
- Verification of identity through documentary or non-documentary methods
- Screening against government watchlists and sanctions databases
- Retention of identification records for the required period
5. Enhanced Due Diligence (EDD)
We apply enhanced due diligence measures to higher-risk customers, including:
- Politically Exposed Persons (PEPs) and their family members or close associates
- Customers from high-risk jurisdictions
- Complex ownership structures or unusual business arrangements
- Customers with negative news or adverse media coverage
- Unusual or suspicious transaction patterns
6. Transaction Monitoring
We employ sophisticated transaction monitoring systems to detect suspicious activities, including:
Automated Monitoring
Real-time and batch monitoring systems that flag unusual transaction patterns, velocity, and amounts.
Risk-Based Thresholds
Customized thresholds based on customer risk profiles and expected transaction behavior.
Alert Investigation
Trained compliance staff review and investigate flagged transactions to determine if suspicious activity reporting is required.
7. Suspicious Activity Reporting
When we detect activity that we know, suspect, or have reason to suspect involves funds derived from illegal activity, is designed to evade reporting requirements, lacks a lawful purpose, or involves the use of our platform to facilitate criminal activity, we will file a Suspicious Activity Report (SAR) with FinCEN within the required timeframe. We maintain strict confidentiality regarding SAR filings and do not disclose the existence of such reports to the subjects of the reports.
8. Sanctions Compliance
We maintain a comprehensive sanctions compliance program that includes:
- Screening all customers against OFAC's Specially Designated Nationals (SDN) List
- Screening against other relevant sanctions lists (UN, EU, UK, etc.)
- Blocking transactions involving sanctioned parties or jurisdictions
- Ongoing monitoring for changes to sanctions designations
9. Recordkeeping
We maintain comprehensive records of all customer identification information, transaction records, and AML-related documentation for a minimum of five years, or longer if required by applicable law. Records are maintained in a manner that allows for timely retrieval in response to regulatory inquiries or legal requests.
10. Red Flags
Our staff is trained to recognize potential red flags, including but not limited to:
- Reluctance to provide complete identification information
- Providing false, misleading, or substantially incorrect information
- Unusual transaction patterns inconsistent with stated purpose
- Transactions with no apparent economic or lawful purpose
- Structuring transactions to avoid reporting thresholds
- Connections to high-risk jurisdictions or sanctioned countries
11. Cooperation with Law Enforcement
We cooperate fully with law enforcement agencies and regulatory authorities in their efforts to combat money laundering and terrorist financing. This includes responding to subpoenas, court orders, and other lawful requests for information in a timely manner.
12. Policy Updates
This AML Policy is reviewed and updated periodically to reflect changes in regulatory requirements, industry best practices, and our business operations. Material updates will be communicated through our website.
For questions about our AML program or to report suspicious activity, please contact us at:
Commertize, Inc.
Attn: AML Compliance Officer
20250 SW Acacia St. #130
Newport Beach, California 92660
Email: compliance@commertize.com