BSA/AML Program

MoneyFlap Policy

MoneyFlap strictly enforces policies against money laundering and activities supporting terrorism or crime, abiding by the Bank Secrecy Act (BSA), European Union (EU) regulations, and rules of any supported jurisdictions. Their Anti-Money Laundering (AML) policies and internal controls ensure compliance, with regular reviews and updates to align with regulatory changes and company developments.

MoneyFlap strictly enforces policies against money laundering and activities supporting terrorism or crime, abiding by the Bank Secrecy Act (BSA), European Union (EU) regulations, and rules of any supported jurisdictions. Their Anti-Money Laundering (AML) policies and internal controls ensure compliance, with regular reviews and updates to align with regulatory changes and company developments.

AML Compliance Person Designation and Duties

Checking the Office of Foreign Assets Control (OFAC) Listings

Before opening an account and continuously thereafter, we'll ensure customers aren't on the SDN list or involved in prohibited transactions per OFAC's economic sanctions and embargoes. Since these lists are frequently updated, we will regularly check them and subscribe to updates.

Before opening an account and continuously thereafter, we'll ensure customers aren't on the SDN list or involved in prohibited transactions per OFAC's economic sanctions and embargoes. Since these lists are frequently updated, we will regularly check them and subscribe to updates.

Customer Identification Program (CIP)

We have a written Customer Identification Program (CIP) in place. For every new account, we collect essential identification details, use risk-based methods to yerify identities, record the information and verification results, give customers a notice about the need for identification, and check their information against government lists of suspected terrorists.

We have a written Customer Identification Program (CIP) in place. For every new account, we collect essential identification details, use risk-based methods to yerify identities, record the information and verification results, give customers a notice about the need for identification, and check their information against government lists of suspected terrorists.

Customer Due Diligence Rule

Before opening an account, we will collect the following information for all accounts, if applicable, for any person, that is opening a new account and whose name is on the account:

Full legal name;

Mobile phone number;

Date of birth;

Email address;

A residential street address;

A identification number, which will be one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons); and

A identification number, which will be one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons); and

Additional details or documents may be required by our Compliance Team.

We will understand the nature and purpose of customer relationships to develop a customer risk profile. The risk assessment of the client will then place them in one of the levels of customer due diligence, which determines the risk rating and KYC checks that will be performed

We will understand the nature and purpose of customer relationships to develop a customer risk profile. The risk assessment of the client will then place them in one of the levels of customer due diligence, which determines the risk rating and KYC checks that will be performed

Monitoring Accounts for Suspicious Activity

At MoneyFlap, we will monitor accounts for unusual transactions, considering relevant risk factors and red flags. Detected activities will be reviewed and documented by our monitoring system. The AML Compliance Person or a designee will investigate and review necessary information from internal or third-party sources before filing a SAR.

At MoneyFlap, we will monitor accounts for unusual transactions, considering relevant risk factors and red flags. Detected activities will be reviewed and documented by our monitoring system. The AML Compliance Person or a designee will investigate and review necessary information from internal or third-party sources before filing a SAR.

Suspicious Activity and Currency Transactions Reporting

We will file Suspicious Activity Reports (SARs) with FinCEN for any transactions involving funds or assets that we suspect or have reason to suspect are suspicious. Additionally, we will notify law enforcement in cases requiring immediate attention, such as terrorist financing or ongoing money laundering. We will submit Currency Transaction Reports (CTRs) to FinCEN for individual or multiple currency transactions that exceed a specified USD amount within a single business day, if they are made by or on behalf of the same person.

We will file Suspicious Activity Reports (SARs) with FinCEN for any transactions involving funds or assets that we suspect or have reason to suspect are suspicious. Additionally, we will notify law enforcement in cases requiring immediate attention, such as terrorist financing or ongoing money laundering. We will submit Currency Transaction Reports (CTRs) to FinCEN for individual or multiple currency transactions that exceed a specified USD amount within a single business day, if they are made by or on behalf of the same person.

AML Recordkeeping

Our designated AML Compliance Person will ensure proper maintenance of AML records and the filing of SARs. Our firm will create and keep SARs, customer identity verification, and funds transmittal documentation for at least six years, maintaining their confidentiality. Disclosure will be limited to FinCEN, the SEC, an SEC-registered SRO, or other relevant legal authorities.

Our designated AML Compliance Person will ensure proper maintenance of AML records and the filing of SARs. Our firm will create and keep SARs, customer identity verification, and funds transmittal documentation for at least six years, maintaining their confidentiality. Disclosure will be limited to FinCEN, the SEC, an SEC-registered SRO, or other relevant legal authorities.

Training Programs

We will implement continuous employee training led by the AML Compliance Person and senior management, at least annually. The training will be tailored to MoneyFlap’s size, customer base, and resources, and updated for new legal developments. We will keep records of trained individuals, training dates, and topics covered. Additionally, we will assess if certain employees need specialized extra training.

We will implement continuous employee training led by the AML Compliance Person and senior management, at least annually. The training will be tailored to MoneyFlap’s size, customer base, and resources, and updated for new legal developments. We will keep records of trained individuals, training dates, and topics covered. Additionally, we will assess if certain employees need specialized extra training.

Program to Independently Test AML Program

Our AML program will be independently tested at least once a year. After testing, the findings will be reported to senior management. We will promptly address and document how each issue is resolved.

Monitoring Employee Conduct and Accounts

Employee accounts will undergo the same Anti-Money Laundering (AML) procedures as customer accounts, supervised by the AML Compliance Person. Supervisors' AML performance will be evaluated during their annual review, and the CEO will review the AML Compliance Person's accounts.

Employee accounts will undergo the same Anti-Money Laundering (AML) procedures as customer accounts, supervised by the AML Compliance Person. Supervisors' AML performance will be evaluated during their annual review, and the CEO will review the AML Compliance Person's accounts.