1. Policy Statement
Fundsunite INC is committed to preventing money laundering and terrorist financing activities through our platform. We maintain a comprehensive Anti-Money Laundering (AML) program in compliance with applicable laws and regulations.
2. Risk Assessment
2.1 Customer Risk Categories:
- Low Risk: Verified individuals with transparent funding sources
- Medium Risk: Business entities, high-value transactions
- High Risk: Politically Exposed Persons (PEPs), high-risk jurisdictions
2.2 Transaction Risk Factors:
- Unusual transaction patterns
- Rapid movement of funds
- Transactions with high-risk jurisdictions
- Inconsistent with stated project purposes
3. Customer Due Diligence (CDD)
3.1 Identity Verification:
Individual Users:
- Government-issued photo identification
- Proof of address documentation
- Tax identification number verification
- Biometric verification (enhanced cases)
Business Entities:
- Certificate of incorporation
- Beneficial ownership identification
- Business registration documents
- Authorized representative verification
3.2 Enhanced Due Diligence (EDD):
Applied to:
- PEPs and their close associates
- Users from high-risk jurisdictions
- Unusual or complex transaction patterns
- Cash-intensive business projects
4. Transaction Monitoring
4.1 Automated Monitoring:
Real-time transaction screening
Pattern recognition algorithms
Threshold-based alerts
Behavioral analysis
4.2 Manual Review:
- Suspicious activity investigation
- Enhanced due diligence cases
- Regulatory reporting preparation
- Law enforcement coordination
5. Reporting Obligations
5.1 Suspicious Activity Reports (SARs):
We file SARs with FinCEN for:
- Known or suspected violation of law
- Transactions over $5,000 involving criminal activity
- Attempts to avoid reporting requirements
5.2 Currency Transaction Reports (CTRs):
Required for cash transactions exceeding $10,000 in one business day.
6. Record Keeping
6.1 Retention Period:
- Customer identification records: 5 years after account closure
- Transaction records: 5 years from transaction date
- SARs and supporting documentation: 5 years from filing date
6.2 Record Types:
- Customer identification and verification documents
- Account files and business correspondence
- Transaction records and statements
- AML program documentation and training records
7. Sanctions Compliance
We screen all users against:
- Office of Foreign Assets Control (OFAC) lists
- United Nations Security Council sanctions
- European Union sanctions regimes
- Other relevant national and international sanctions
8. Training Program
8.1 Employee Training:
Annual AML compliance training
Suspicious activity recognition
Regulatory updates and changes
Case studies and practical applications
8.2 Management Training:
- Risk assessment methodologies
- Regulatory examination preparation
- Program oversight and improvement
- Executive responsibility understanding
9. Independent Testing
Our AML program undergoes:
- Annual internal audits
- Biannual external independent reviews
- Regulatory examination compliance
- Continuous program improvement
10. Compliance Officer
- AML Compliance Officer
- Fundsunite INC
- Suite 850, Brickell Financial Centre
- 80 SW 8th Street
- Miami, FL 33130
- Email: compliance@fundsunite.com
11. Jurisdictional Compliance
We maintain compliance with:
- Bank Secrecy Act (BSA)
- USA PATRIOT Act
- Financial Action Task Force (FATF) recommendations
- Local and international AML regulations
