🛡️ Anti-Money Laundering Policy

1. Policy Overview

GiftKori LLC ("Company," "we," "us," or "our") is committed to preventing money laundering and terrorist financing activities on our gift card exchange platform. This Anti-Money Laundering (AML) Policy outlines our compliance measures, reporting procedures, and regulatory obligations in accordance with applicable federal and state laws.

2. Regulatory Framework

2.1 Applicable Laws

Our AML program complies with:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Anti-Money Laundering Act of 2020
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• State money transmission laws where applicable

2.2 Risk Assessment

We conduct regular risk assessments considering:

• Customer demographics and transaction patterns
• Geographic risk factors
• Product and service risk profiles
• Delivery channel vulnerabilities

3. Customer Due Diligence (CDD)

3.1 Customer Identification Program (CIP)

All customers must provide the following information:

• Full legal name
• Date of birth
• Physical address (not P.O. Box)
• Government-issued identification number
• Phone number and email address

3.2 Identity Verification

We verify customer identities through:

• Government-issued photo identification documents
• Third-party identity verification services
• Address verification procedures
• Phone number verification

3.3 Enhanced Due Diligence (EDD)

Enhanced measures are applied for:

• High-value transactions exceeding $3,000
• Customers from high-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Customers with unusual transaction patterns

4. Transaction Monitoring

4.1 Automated Monitoring Systems

Our systems monitor transactions for:

• Unusual transaction amounts or frequencies
• Structured transactions to avoid reporting thresholds
• Rapid movement of funds between accounts
• Transactions with sanctioned entities or jurisdictions

4.2 Red Flag Indicators

Transactions are flagged for review when:

• Customer provides inconsistent information
• Unusual geographic patterns in transactions
• High-value transactions inconsistent with customer profile
• Reluctance to provide required documentation
• Use of multiple accounts or payment methods

5. Suspicious Activity Reporting

5.1 SAR Filing Requirements

We file Suspicious Activity Reports (SARs) when:

• Transactions involve $2,000 or more in suspicious activity
• Money laundering is suspected regardless of amount
• Violations of federal law are detected
• Transactions have no apparent lawful purpose

5.2 Investigation Process

Our investigation procedures include:

• Initial review by compliance team within 24 hours
• Enhanced investigation for complex cases
• Documentation of findings and decisions
• SAR filing within 30 days if required

6. Record Keeping Requirements

6.1 Customer Records

We maintain records of:

• Customer identification information for 5 years after account closure
• Transaction records for 5 years from transaction date
• Suspicious activity investigations and SARs
• Training records and compliance documentation

6.2 Transaction Documentation

Transaction records include:

• Date, amount, and nature of transaction
• Customer identification and verification details
• Source and destination of funds
• Any supporting documentation

7. OFAC Sanctions Compliance

7.1 Sanctions Screening

We screen all customers and transactions against:

• OFAC Specially Designated Nationals (SDN) List
• Consolidated Sanctions List
• Foreign Sanctions Evaders List
• Sectoral Sanctions Identifications List

7.2 Blocked Transactions

When sanctions matches occur:

• Transactions are immediately blocked
• Assets are frozen pending investigation
• OFAC is notified within required timeframes
• Detailed records are maintained

8. Training and Awareness

8.1 Employee Training

All employees receive training on:

• AML laws and regulations
• Money laundering typologies
• Red flag identification
• Reporting procedures
• Customer due diligence requirements

8.2 Ongoing Education

Training programs include:

• Annual AML training for all staff
• Specialized training for compliance personnel
• Updates on regulatory changes
• Case study reviews and lessons learned

9. Geographic Risk Management

9.1 High-Risk Jurisdictions

Enhanced monitoring applies to transactions involving:

• Countries identified by FATF as high-risk
• Jurisdictions with weak AML controls
• Countries subject to U.S. sanctions
• Areas with known terrorist financing risks

9.2 Risk Mitigation

For high-risk jurisdictions, we implement:

• Enhanced customer due diligence
• Additional transaction monitoring
• Senior management approval requirements
• Increased record keeping standards

10. Third-Party Risk Management

10.1 Vendor Due Diligence

Third-party service providers undergo:

• AML compliance assessment
• Background checks and reference verification
• Ongoing monitoring and review
• Contractual compliance requirements

10.2 Payment Processor Oversight

We ensure payment partners maintain:

• Adequate AML programs
• Proper licensing and registration
• Compliance with reporting requirements
• Regular compliance certifications

11. Compliance Program Management

11.1 Program Oversight

Our AML program includes:

• Designated AML compliance officer
• Board-level oversight and reporting
• Regular program effectiveness reviews
• Independent compliance testing

11.2 Continuous Improvement

We regularly update our program through:

• Regulatory guidance reviews
• Industry best practice adoption
• Technology system enhancements
• Policy and procedure updates

12. Customer Responsibilities

Customers are expected to:

• Provide accurate identification information
• Report any suspicious activities
• Comply with transaction limits and requirements
• Cooperate with compliance investigations
• Notify us of changes to personal information

13. Contact Information

For AML compliance questions or to report suspicious activities:

14. Policy Updates

This AML Policy may be updated periodically to reflect changes in regulations, business practices, or risk assessments. Material changes will be communicated to affected parties and published on our website.

15. Effective Date

This Anti-Money Laundering Policy is effective as of December 23, 2024, and applies to all GiftKori operations and customer relationships from that date forward.