Anti-Money Laundering Policy

Last Updated: December 2024

1. Introduction

VS Global Connect is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures and controls to prevent the use of our services for money laundering or terrorist financing activities.

2. Regulatory Framework

Our AML policy is designed to comply with:

• Financial Action Task Force (FATF) recommendations
• Local regulatory requirements
• International best practices for financial services
• Know Your Customer (KYC) standards

3. Customer Due Diligence (CDD)

Standard Due Diligence

For all customers, we require:

• Government-issued photo identification (passport, national ID)
• Proof of residential address (utility bill, bank statement)
• Verification of contact information
• Source of funds declaration

Enhanced Due Diligence (EDD)

Additional measures are applied for:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex or unusual transactions
• High-value accounts

4. Know Your Customer (KYC) Procedures

Our KYC process includes:

• Identity verification through document checks
• Address verification
• Screening against sanctions lists and PEP databases
• Risk assessment and categorization
• Ongoing monitoring of customer activity

5. Transaction Monitoring

We employ sophisticated monitoring systems to:

• Detect unusual or suspicious transaction patterns
• Monitor for structuring or layering activities
• Track cumulative transaction volumes
• Identify potential terrorist financing indicators

6. Suspicious Activity Reporting

We are obligated to:

• Report suspicious transactions to relevant authorities
• Maintain records of all suspicious activity reports
• Cooperate with law enforcement investigations
• Not tip off customers about investigations

7. Record Keeping

We maintain comprehensive records including:

• Customer identification documents for at least 5 years
• Transaction records and account history
• Internal correspondence regarding suspicious activities
• Training records for staff

8. Staff Training

All employees receive regular training on:

• AML policies and procedures
• Recognizing suspicious activities
• Customer due diligence requirements
• Reporting obligations

9. Prohibited Activities

We do not accept customers or transactions involving:

• Sanctioned individuals or entities
• Shell companies without legitimate business purpose
• Anonymous or fictitious accounts
• Jurisdictions subject to comprehensive sanctions

10. Compliance Officer

Our designated AML Compliance Officer is responsible for:

• Overseeing the AML program
• Ensuring regulatory compliance
• Reporting to senior management and regulators
• Updating policies as regulations evolve

11. Contact

For questions about our AML policy, please contact our Compliance Department at compliance@vsglobalconnect.com.