ANTI-MONEY LAUNDERING (AML) POLICY
Last updated: November 15, 2025
VybMate is committed to preventing money laundering and terrorist financing activities on our platform. This Anti-Money Laundering Policy outlines our procedures and requirements to ensure compliance with applicable AML regulations.
1. POLICY OVERVIEW
1.1 Commitment
- Zero tolerance for money laundering activities
- Compliance with all applicable AML laws and regulations
- Cooperation with law enforcement and regulatory authorities
- Regular monitoring and reporting of suspicious activities
1.2 Scope
- All users, transactions, and activities on the VybMate platform
- All employees, contractors, and business partners
- All payment methods and financial transactions
- All jurisdictions where VybMate operates
2. CUSTOMER DUE DILIGENCE (CDD)
2.1 Identity Verification
- Government-issued photo ID required for all users
- Address verification for enhanced due diligence
- Biometric verification where technically feasible
- Regular re-verification for high-risk users
2.2 Enhanced Due Diligence (EDD)
- Additional verification for high-value transactions
- Source of funds documentation when required
- Politically Exposed Person (PEP) screening
- Sanctions and watchlist screening
2.3 Ongoing Monitoring
- Transaction pattern analysis
- Behavioral monitoring and anomaly detection
- Regular review of user profiles and activities
- Risk assessment updates based on user behavior
3. TRANSACTION MONITORING
3.1 Automated Systems
- Real-time transaction monitoring systems
- Machine learning algorithms for pattern detection
- Risk scoring based on transaction characteristics
- Automated alerts for suspicious activities
3.2 Manual Reviews
- Investigation of flagged transactions
- Analysis of unusual transaction patterns
- Review of high-value or high-frequency transactions
- Assessment of cross-border payment activities
4. SUSPICIOUS ACTIVITY REPORTING
4.1 Identification Criteria
- Transactions inconsistent with user profiles
- Unusually large or frequent transactions
- Structured transactions to avoid reporting thresholds
- Transactions with high-risk jurisdictions
4.2 Reporting Procedures
- Internal escalation to compliance team
- Documentation of suspicious activities
- Filing of Suspicious Activity Reports (SARs) when required
- Cooperation with law enforcement investigations
5. RECORD KEEPING
5.1 Transaction Records
- All payment and transaction data retained for minimum 5 years
- Customer identification records maintained
- Communication records preserved
- Audit trails for all system activities
5.2 Compliance Documentation
- AML training records for employees
- Risk assessment and due diligence documentation
- Suspicious activity reports and investigations
- Regulatory correspondence and filings
6. TRAINING AND AWARENESS
6.1 Employee Training
- Regular AML training for all staff
- Specialized training for compliance personnel
- Updates on regulatory changes and requirements
- Assessment of training effectiveness
6.2 User Education
- Information about AML requirements
- Guidance on acceptable platform usage
- Warning signs of potential money laundering
- Reporting mechanisms for suspicious activities
7. PROHIBITED ACTIVITIES
7.1 Forbidden Transactions
- Transactions involving illegal activities
- Payments to or from sanctioned individuals or entities
- Structured transactions to evade detection
- Use of multiple accounts to circumvent limits
7.2 Account Restrictions
- Immediate suspension for suspected AML violations
- Restriction of transaction privileges
- Enhanced monitoring for high-risk accounts
- Account termination for confirmed violations
8. COMPLIANCE MONITORING
8.1 Internal Audits
- Regular assessment of AML controls
- Testing of monitoring systems effectiveness
- Review of policies and procedures
- Compliance with regulatory requirements
8.2 External Oversight
- Independent audit of AML program
- Regulatory examinations and inspections
- Third-party risk assessments
- Corrective action implementation
9. SANCTIONS COMPLIANCE
9.1 Screening Procedures
- Real-time sanctions screening for all users
- Transaction screening against sanctions lists
- Regular updates of sanctions databases
- Blocking of prohibited transactions
9.2 List Management
- OFAC, UN, EU, and other sanctions lists
- Politically Exposed Person (PEP) databases
- Adverse media and law enforcement databases
- Regular updates and system maintenance
10. REGULATORY COOPERATION
10.1 Reporting Requirements
- Timely filing of required AML reports
- Response to regulatory inquiries and requests
- Cooperation with law enforcement investigations
- Compliance with court orders and subpoenas
10.2 Information Sharing
- Sharing of information with law enforcement
- Cooperation with other financial institutions
- Participation in industry AML initiatives
- Support for regulatory examinations
11. CONSEQUENCES OF NON-COMPLIANCE
Violations of this AML Policy may result in:
- Immediate account suspension or termination
- Reporting to law enforcement authorities
- Civil and criminal penalties
- Legal action and prosecution
12. POLICY UPDATES
This AML Policy is reviewed regularly and updated to reflect:
- Changes in applicable laws and regulations
- Evolution of money laundering techniques
- Technological developments and capabilities
- Regulatory guidance and best practices
13. CONTACT INFORMATION
For AML compliance questions or to report suspicious activities:
- Email: compliance@vybmate.com
- Compliance Hotline: [Phone Number]
- Secure reporting portal on our platform
- Written correspondence to our compliance department
VybMate is committed to maintaining the highest standards of AML compliance to protect our platform, users, and the broader financial system from money laundering and terrorist financing activities.