Anti-Money Laundering Policy

Overview

MonxoBank is committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. We have implemented a comprehensive AML/CTF program designed to prevent, detect, and report suspicious activities.

Our AML Program

1. Know Your Customer (KYC)

We verify the identity of all customers through a robust KYC process that includes:

• Government-issued photo identification verification
• Proof of residential address
• Biometric verification (facial recognition)
• Sanctions and PEP (Politically Exposed Person) screening
• Adverse media screening

2. Transaction Monitoring

We employ advanced AI and machine learning systems to monitor all transactions for:

• Unusual transaction patterns
• Structuring (smurfing) attempts
• High-risk jurisdictions
• Sanctions list matches
• Suspicious counterparty activities

3. Enhanced Due Diligence (EDD)

For higher-risk customers and transactions, we conduct Enhanced Due Diligence which includes:

• Source of wealth verification
• Source of funds documentation
• Additional identity verification measures
• Senior management approval
• Ongoing enhanced monitoring

4. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with relevant financial intelligence units when we detect activities that may indicate money laundering, terrorist financing, or other financial crimes.

Record Keeping

We maintain comprehensive records of all transactions, customer identifications, and compliance activities for a minimum of 7 years, in accordance with applicable regulations.

Sanctions Compliance

We comply with all applicable sanctions programs, including those administered by:

• United States (OFAC)
• European Union
• United Kingdom (OFSI)
• United Nations Security Council

Reporting Violations

If you suspect any suspicious activity or violations of our AML policies, please report it immediately to compliance@monxobank.com.