Anti-Money Laundering (AML) Policy

1. Policy Overview

BANKTO is committed to maintaining the highest standards of integrity and compliance with anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations. This AML Policy establishes the framework and procedures through which BANKTO identifies, monitors, and reports suspicious activities.

This policy applies to all employees, contractors, partners, and users of BANKTO's platform. Compliance with this policy is mandatory and non-negotiable.

2. Know Your Customer (KYC) Procedures

BANKTO implements comprehensive KYC procedures to verify the identity and legitimacy of all users and customers. KYC requirements include:

All KYC information is collected, verified, and maintained in accordance with applicable regulations and BANKTO's data retention policies.

3. Enhanced Due Diligence (EDD)

For customers presenting elevated risk profiles, BANKTO implements Enhanced Due Diligence (EDD) procedures, including:

• •Politically Exposed Persons (PEPs): Identification and enhanced screening of customers who are or have been entrusted with prominent public functions
• •High-Risk Jurisdictions: Enhanced scrutiny of customers from jurisdictions identified as high-risk for money laundering or terrorist financing
• •High-Risk Industries: Additional verification for customers in industries with elevated AML risk (casinos, precious metals dealers, real estate)
• •Large Transaction Customers: Enhanced monitoring of customers initiating large or unusual transactions
• •Ongoing Monitoring: Continuous monitoring of customer transactions and periodic re-verification of customer information

4. Sanctions Screening

BANKTO maintains a comprehensive sanctions screening program to ensure compliance with international sanctions regimes, including:

• •OFAC Screening: Screening against US Office of Foreign Assets Control (OFAC) designated persons and entities lists
• •UN Sanctions Lists: Screening against United Nations Security Council sanctions lists
• •EU Sanctions Lists: Screening against European Union consolidated sanctions lists
• •Other Jurisdictional Lists: Screening against sanctions lists maintained by other relevant jurisdictions

All customers and transaction counterparties are screened against these lists at account opening and on an ongoing basis. Any matches or potential matches trigger immediate investigation and escalation.

5. Transaction Monitoring

BANKTO employs sophisticated transaction monitoring systems to detect suspicious patterns and activities. Monitoring parameters include:

• •Unusual transaction amounts relative to customer profile and historical patterns
• •Rapid movement of funds in and out of accounts (structuring or "smurfing")
• •Transactions with high-risk jurisdictions or sanctioned countries
• •Transactions inconsistent with stated business purpose
• •Multiple transactions to different beneficiaries in short timeframes
• •Use of intermediaries or shell companies in transactions
• •Round-dollar transactions or transactions designed to avoid reporting thresholds

6. Suspicious Activity Reporting (SAR)

BANKTO maintains procedures to identify and report suspicious activities to relevant financial intelligence units and regulatory authorities. Suspicious activities include:

• •Transactions involving proceeds of crime or terrorist financing
• •Structuring or deliberate evasion of reporting requirements
• •Use of false or misleading information in customer identification
• •Transactions with sanctioned persons or entities
• •Transactions that deviate significantly from customer profile

SARs are filed within the timeframe required by applicable law, typically within 10 business days of detection. BANKTO maintains strict confidentiality regarding SAR filings and does not disclose SAR information to customers.

7. Currency Transaction Reporting (CTR)

BANKTO files Currency Transaction Reports (CTRs) for all transactions exceeding applicable thresholds (typically $10,000 USD or equivalent) as required by law. CTRs are filed with relevant financial intelligence units and include transaction details, customer information, and counterparty information.

8. Customer Risk Classification

BANKTO classifies customers into risk categories (Low, Medium, High) based on factors including customer type, jurisdiction, business activities, transaction patterns, and compliance history. Risk classification determines the level of due diligence, monitoring, and reporting required.

9. Staff Training & Awareness

All BANKTO employees receive mandatory AML/CTF training upon hire and annually thereafter. Training covers:

• •Recognition of money laundering and terrorist financing indicators
• •KYC and due diligence procedures
• •Sanctions screening and compliance
• •Reporting obligations and procedures
• •Confidentiality and non-tipping off requirements

10. Compliance Officer & Governance

BANKTO designates a Chief Compliance Officer responsible for overseeing AML/CTF compliance, reporting to senior management and the board of directors. The Compliance Officer has authority to:

• •Implement and enforce AML/CTF policies and procedures
• •Investigate suspicious activities and transactions
• •File SARs and other regulatory reports
• •Restrict or terminate customer accounts for AML concerns
• •Conduct internal audits and compliance reviews

11. Record Keeping & Documentation

BANKTO maintains comprehensive records of all KYC documentation, transaction details, monitoring results, and compliance activities. Records are retained for a minimum of 5-7 years as required by applicable regulations and are available for inspection by regulatory authorities upon request.

12. Third-Party Risk Management

BANKTO conducts due diligence on third-party service providers, partners, and intermediaries to ensure they maintain equivalent AML/CTF standards. Third-party agreements include AML compliance obligations and audit rights.

13. Policy Review & Updates

This AML Policy is reviewed annually and updated to reflect changes in regulatory requirements, industry best practices, and emerging threats. All updates are communicated to relevant staff and incorporated into training programs.

14. Reporting & Contact

For questions about this AML Policy or to report suspected money laundering or terrorist financing activities, please contact: