Anti-Money Laundering (AML) Policy

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Anti-Money Laundering (AML) Execution Plan

Company Name: INFINITY LABS LIMITED
Date: 22.01.2025
Version: 1.2

1. Purpose and Scope

This Anti-Money Laundering (AML) Execution Plan ensures that INFINITY LABS LIMITED complies with relevant AML and Counter-Terrorist Financing (CFT) laws and regulations. It aims to prevent money laundering and terrorist financing risks. This plan applies to all financial transactions, with a focus on OTC trading activities on Binance within New Zealand.

2. Transaction Monitoring and Rules

Transaction Monitoring Scope

The Company monitors all financial transactions, including fiat and cryptocurrency transactions, particularly OTC trading on Binance.

Transaction Monitoring Tools

The Sumsub system is used for transaction monitoring. It automatically analyzes transaction activities and customer behaviors based on predefined rules.

Monitoring Rules

· Large Transaction Monitoring: Transactions exceeding USD 5,000 are flagged as high-risk and require further review by the compliance team.

· Frequent Transaction Monitoring: More than 10 transactions per day trigger an alert for further investigation.

· Anomaly Detection: Unusual patterns (e.g., sudden large sums or frequent cross-border transactions) automatically generate alerts for compliance review.

Monitoring Thresholds

· Low-Risk Customers: Transactions above USD 10,000 are considered high-risk.

· Medium-Risk Customers: Transactions above USD 5,000 trigger an alert.

· High-Risk Customers: Transactions above USD 2,000 are considered high-risk.

Alerts and Reports

All high-risk transactions generate an automatic alert, including transaction details and customer identity. The compliance team investigates and determines further actions.

3. Risk Assessment and Customer Classification

Customer Risk Levels

· Low-Risk Customers: From low-risk countries, with stable transaction patterns and moderate transaction frequency.

· Medium-Risk Customers: From medium-risk countries, engaging in moderate transaction frequency or occasional large transactions.

· High-Risk Customers: From high-risk countries or exhibiting complex funding sources, unstable transaction behavior, or frequent large transactions.

Country Risk Classification

· Low-Risk Countries: Countries with high AML/CFT standards (e.g., Singapore, Switzerland).

· Medium-Risk Countries: Countries with some AML/CFT deficiencies but no high-risk designation.

· High-Risk Countries: Countries identified as high-risk by FATF or similar organizations (e.g., under sanctions or with high corruption levels).

4. Name Screening

Tool Used

The Sumsub system screens customer names against global sanctions lists, including OFAC, UN, EU, and Binance-specific lists.

Screening Process

· Initial Screening: Performed before establishing any business relationship.

· Ongoing Screening: Conducted periodically to update and validate customer information.

If a customer's name matches any entity on the sanctions lists, they are flagged as high-risk, and transactions are prohibited.

5. Enhanced Due Diligence (EDD)

Customer Due Diligence (CDD) Requirements

· Identity Verification: Collect and verify valid ID (e.g., passport, driver's license) and proof of address.

· Risk Assessment: Evaluate the customer's background and assign a risk level.

· Ongoing Monitoring: Regularly review customer activities.

Enhanced Due Diligence (EDD) for High-Risk Customers

· Background Check: Analyze the client's history for illegal activities.

· Source of Funds Verification: Confirm the legitimacy of funds.

· Transaction Monitoring: Closely examine transaction patterns.

Additional Requirements for Politically Exposed Persons (PEPs):

· Senior management approval is required.

· Source of wealth and funds must be verified.

· Enhanced ongoing monitoring is mandatory.

6. Periodic Review

· High-Risk Customers: Reviewed every 3 months.

· Medium-Risk Customers: Reviewed every 6 months.

· Low-Risk Customers: Reviewed annually.

Reviews evaluate changes in customer behavior, identity, and risk classification.

7. Employee Training

· Frequency: Annual training on AML laws, regulations, and company policies.

· Content: 

o Basics of AML/CFT compliance.

o Internal policies and procedures.

o Identifying and reporting suspicious transactions.

o Managing high-risk customers.

Appendix

1. Sumsub System Features

· Customer Identity Verification: Supports multiple ID types (passport, driver's license).

· Name Screening: Flags names against global sanctions and adverse media lists.

· Transaction Monitoring: Real-time monitoring and automated report generation.

2. KYC Records Retention

KYC records are retained for a minimum of 5 years, including identity verification and suspicious activity reports.

3. Reporting Suspicious Activities

Suspicious activities are reported to the Financial Markets Authority (FMA) of New Zealand and the New Zealand Police.