1. Firm Policy

It is the policy of MoneyPipe to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Money Laundering and Terrorism (Prevention) Act, Money Laundering and Terrorism (Prevention) Act Guidelines, Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines, FATF recommendations, and its implementing regulations.

Generally speaking, the money laundering process consists of three “stages”:

These “stages” are not static and overlap broadly. Financial institutions may be misused at any point in the money laundering process.

MoneyPipe is committed to the highest standards of anti-money laundering (AML) compliance and requires management and employees to adhere to these standards to prevent the use of our products and services for money laundering purposes. MoneyPipe will examine its Anti Money Laundering strategies, goals, and objectives on an ongoing basis and maintain an effective Anti-Money Laundering program for the Company’s business that reflects the best practices for a diversified, global financial company. Adherence to the MoneyPipe Anti-Money Laundering Program is the responsibility of all employees. The program includes client screening and monitoring requirements, “know your customer” policies (including the requirement to establish the identity of beneficial owners), Embargo policies, record keeping requirements, the reporting of suspicious circumstances in accordance with relevant laws, and training.

2. AML Compliance Person

MoneyPipe has designated its Compliance Officer (CO) as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. CO has a working knowledge of compliance requirements and its implementing regulations and is qualified by experience, knowledge, and training. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication, and training for employees. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious transaction reports (STR) are filed with the Financial Intelligence Unit (FIU) when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.

MoneyPipe will provide the Authorities with contact information for the AML Compliance Person, including: (1) name; (2) title; (3) mailing address; (4) email address; and (5) telephone number. The firm will promptly notify the Authority of any change in this information and will review, and if necessary update, this information within 14 business days after the end of each calendar year. The annual review of FCS information will be conducted by CO and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, CO will update the information promptly, but in any event not later than 30 days following the change.