Squaretalk Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

Squaretalk (hereafter referred to as “the Company”) is steadfast in its commitment to uphold the highest standards of legal and ethical conduct. This policy articulates the Company’s unwavering dedication to identifying, mitigating, and managing the risks associated with money laundering and terrorist financing that may be related to our products and services.

Definition of Money Laundering and Terrorist Financing

The Company acknowledges money laundering as the process of disguising illegally obtained funds to appear as though they originated from legitimate sources. Similarly, terrorist financing is recognized as the act of providing financial support to individuals or organizations involved in terrorist activities.

Objectives of the Company’s AML/CTF Policy

Our AML/CTF policy is a reflection of our global commitment to combatting financial crimes. It establishes universal standards that are in line with both regulatory requirements and ethical obligations in all markets where we operate. This policy is instrumental in maintaining the integrity and stability of the global financial system, while also safeguarding the Company from reputational harm and legal repercussions.

Core Principles of the Policy

The Company adheres to the following principles:

1. Opposition to Financial Crimes: The Company is firmly against money laundering and terrorist financing and has established a framework to identify and reduce the risk of our services being misused for such illegal activities.
2. Customer Legitimacy: We endeavor to provide our products and services exclusively for lawful purposes to customers whose identities have been verified to a reasonable degree.
3. Resource Allocation: Adequate resources and funding are allocated for the effective implementation and ongoing management of the Company’s AML/CTF Program.
4. Employee Training: All employees are mandated to undergo comprehensive AML/CTF training to fully comprehend their responsibilities under applicable laws, rules, and regulations.
5. Continuous Monitoring: We conduct regular monitoring of our customers, their transactions, and our employees, proportionate to the level of risk they represent for money laundering and terrorist financing.
6. Management of Risks: The Company ensures that new changes in products, business processes, and systems are consistently reviewed to manage and mitigate potential risks associated with money laundering and terrorist financing.

Know Your Customer (KYC)

The Company is committed to adhering to all relevant KYC policies and procedures in the regions of operation. This includes:

• Establishing customer acceptance procedures for identifying high-risk transactions and customers, necessitating enhanced due diligence.
• Verification procedures to determine if customers are involved in criminal activities, including checks against governmental and international lists of prohibited individuals.
• Undertaking Enhanced Due Diligence in situations that present a heightened level of financial crime or reputational risk.
• Periodic review of existing customer records based on a risk-based approach.
• Ongoing transaction monitoring using a risk-based methodology.
• Prohibiting relationships with shell banks.
• Maintaining and retaining accurate records on customer identification and individual transactions for a specified period.

Compliance and Audits

The Company conducts regular compliance reviews and independent audits to ensure the AML/CTF program and its procedures are effectively meeting the established standards.

Suspicious Activity Reporting

Employees are trained to recognize and report any suspicious activities or ‘red flags.’ The Company has established protocols to ensure that any such concerns are escalated to senior management for review.

AML/CTF Training Program

The Company boasts a comprehensive AML/CTF Training Program aimed at educating employees on the implementation and maintenance of the AML/CTF Program. This includes initial training for new employees and ongoing training for all relevant staff members.