Anti-Money Laundering Policy

1. Introduction

Anton Payments, Inc. is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our comprehensive program designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

As a payment processor operating globally, we are subject to various AML laws and regulations, including but not limited to the Bank Secrecy Act (BSA), the USA PATRIOT Act, and similar legislation in other jurisdictions where we operate.

2. Legal and Regulatory Framework

Our AML program is designed to comply with:

United States: Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and state money transmitter laws
European Union: Fourth and Fifth Anti-Money Laundering Directives (4AMLD, 5AMLD)
United Kingdom: Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
Other Jurisdictions: Applicable AML laws and regulations in all countries where we operate

3. AML Program Components

Our AML program consists of the following key components:

3.1 Customer Due Diligence (CDD)

We conduct thorough customer due diligence on all merchants and users, including:

Identity verification (KYC/KYB procedures)
Business verification and licensing checks
Beneficial ownership identification
Risk assessment and customer risk profiling
Ongoing monitoring and periodic reviews

3.2 Enhanced Due Diligence (EDD)

For higher-risk customers, we implement enhanced due diligence measures, including:

Additional identity and business verification
Source of funds verification
Enhanced transaction monitoring
More frequent account reviews
Senior management approval for high-risk relationships

3.3 Transaction Monitoring

We employ automated and manual transaction monitoring systems to detect suspicious activities, including:

Unusual transaction patterns or volumes
Transactions inconsistent with customer profile
Structuring or smurfing activities
Rapid movement of funds (layering)
Transactions with high-risk jurisdictions
Transactions involving sanctioned parties or countries

3.4 Suspicious Activity Reporting

We have established procedures for identifying, investigating, and reporting suspicious activities to appropriate authorities, including:

Filing Suspicious Activity Reports (SARs) with FinCEN (U.S.)
Reporting to Financial Intelligence Units (FIUs) in other jurisdictions
Internal escalation and investigation procedures
Documentation and record-keeping requirements

3.5 Sanctions Screening

We screen all customers and transactions against sanctions lists, including:

Office of Foreign Assets Control (OFAC) sanctions lists
United Nations sanctions lists
European Union sanctions lists
Other applicable sanctions and watchlists

Screening is conducted at onboarding and on an ongoing basis for all transactions.

4. Risk-Based Approach

We employ a risk-based approach to AML compliance, which means we allocate resources and apply controls based on the level of risk presented by each customer, transaction, or business relationship.

Risk Factors Considered:

Customer type and business model
Geographic location and jurisdiction
Transaction patterns and volumes
Payment methods and channels
Regulatory environment and compliance history
Public information and adverse media

5. Record Keeping

We maintain comprehensive records of all AML-related activities, including:

Customer identification and verification documents
Transaction records and monitoring alerts
Suspicious activity reports and investigations
Risk assessments and due diligence reports
Training records and compliance certifications
Policies, procedures, and program updates

Records are maintained in accordance with applicable retention requirements (typically 5-7 years, or longer as required by law).

6. Training and Awareness

All employees receive regular AML training, including:

AML laws and regulations applicable to our business
Recognition of suspicious activities and red flags
Reporting procedures and requirements
Customer due diligence and enhanced due diligence procedures
Sanctions screening and compliance
Record-keeping and documentation requirements

Training is provided upon hire and on an annual basis, with additional training for employees in high-risk areas.

7. Independent Testing and Audit

Our AML program is subject to independent testing and audit on a regular basis to ensure effectiveness and compliance. This includes:

Internal audit reviews
External compliance audits
Regulatory examinations
Remediation of identified deficiencies

8. Designated Compliance Officer

We have designated a Chief Compliance Officer (CCO) responsible for:

Oversight of the AML program
Ensuring compliance with applicable laws and regulations
Reviewing and approving suspicious activity reports
Maintaining relationships with regulators and law enforcement
Providing AML training and guidance

9. Cooperation with Authorities

We fully cooperate with law enforcement, regulatory authorities, and financial intelligence units in the investigation and prevention of money laundering and terrorist financing, while respecting legal requirements for confidentiality and data protection.

10. Prohibited Activities

We prohibit the use of our services for money laundering, terrorist financing, or other financial crimes. Prohibited activities include:

Processing transactions involving proceeds of crime
Facilitating transactions for sanctioned parties or countries
Structuring transactions to avoid reporting requirements
Processing transactions without proper customer identification
Any activity that violates applicable AML laws or regulations

11. Updates to This Policy

This AML Policy is reviewed and updated regularly to reflect changes in laws, regulations, and our business operations. Material changes will be communicated to affected parties as required.

12. Contact

For questions about this AML Policy or to report suspicious activity, please contact:

Anton Payments, Inc.
Chief Compliance Officer
Email: [email protected]
AML Hotline: [email protected]

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