SQUAREFI.CO AML POLICY 

INTRODUCTION

Welcome to squarefi.co, where we prioritize the highest standards of integrity and compliance. As a responsible and ethical entity, we are committed to safeguarding our platform from illicit financial activities, including money laundering and terrorist financing. To uphold our commitment, we have developed this Anti-Money Laundering (AML) Policy, which outlines the measures and procedures we have put in place to prevent and detect any suspicious or unlawful financial activities.

This AML Policy is designed to ensure compliance with all applicable AML laws, regulations, and guidelines in the jurisdictions where we operate. Our goal is to protect our platform, our customers, and the global financial system from the risks associated with financial crime.

Our AML Policy is not only a set of rules and procedures but also reflects our organization's dedication to maintaining a transparent and accountable business environment. We firmly believe that our efforts to combat money laundering and related crimes contribute to the integrity of our platform and the overall financial industry.

As part of our AML efforts, we have implemented robust customer due diligence measures to assess the risk associated with our customers. We diligently verify customer identities and obtain relevant information about their business activities to ensure compliance with AML regulations.

We encourage all employees, officers, directors, agents, and affiliates of SquareFi.Inc. to be vigilant in identifying and reporting any suspicious transactions or activities. Reporting such activities is crucial in protecting the integrity of our platform and fulfilling our responsibilities as a responsible financial entity.

To ensure that our team remains knowledgeable about AML obligations and best practices, we provide regular AML training sessions. This equips our employees with the necessary knowledge to recognize and address potential AML risks effectively.

We have also appointed a designated AML Compliance Officer to oversee the implementation and enforcement of this AML Policy. This officer plays a vital role in investigating and reporting any suspicious activities to relevant authorities, as required by law.

At SquareFi.Inc., we understand the importance of maintaining accurate and up-to-date records. We commit to securely storing transaction records and customer due diligence documents, making them available to regulatory authorities upon request.

This AML Policy is a living document that will be periodically reviewed and updated to ensure its alignment with evolving AML regulations and best practices. Our ongoing commitment to AML compliance is essential in upholding our reputation as a trustworthy and responsible organization.

SQUAREFI.CO AML POLICY STATEMENT 

 

At SquareFi, we are committed to maintaining the highest level of integrity and adhering to strict compliance standards to combat money laundering and related financial crimes. This AML Policy outlines our dedication to preventing illicit financial activities and aligning with all applicable AML laws, regulations, and guidelines.

 

DEFINITIONS

 

Customer Due Diligence (CDD)	Customer Due Diligence is the process of verifying and understanding the identity of a customer and assessing the risk associated with their business activities to prevent money laundering and other illicit financial activities.
Risk assessment	is a process of identifying, analyzing, and evaluating the potential risks related to money laundering and terrorist financing. Organizations use risk assessments to determine the level of risk associated with customers, products, services, and geographic locations. This enables them to implement appropriate risk mitigation measures and allocate resources effectively to combat financial crime.
KYC (Know Your Customer)	is a critical process in which organizations gather and verify the identity and relevant information of their customers. It aims to ensure that customers are genuine and not involved in illegal or suspicious activities. KYC procedures involve collecting personal information, such as identification documents, proof of address, and other relevant details, and conducting risk assessments to categorize customers based on their level of risk. This helps organizations establish and maintain a trustworthy relationship with their customers and comply with AML regulations.
Enhanced Due Diligence (EDD)	is an advanced level of scrutiny applied to high-risk customers or transactions. EDD involves obtaining additional information beyond standard CDD procedures to gain a deeper understanding of the customer's background, source of funds, and the nature of their transactions. It is particularly important for high-net-worth individuals, politically exposed persons (PEPs), and customers from high-risk jurisdictions.
Transaction monitoring	involves the continuous surveillance of customer transactions to detect unusual patterns, suspicious activities, or transactions that deviate from established behavior. Automated monitoring systems use predefined rules and algorithms to identify potentially suspicious activities, triggering further investigation and reporting if necessary.
Suspicious Transaction Report (STR)	is a formal report filed with the relevant authorities by a financial institution or organization when it identifies a transaction that appears to be suspicious or potentially linked to money laundering or terrorist financing. Filing an STR is a legal obligation in many jurisdictions and assists law enforcement agencies in investigating and combating financial crime.
Anti-Fraud	refers to a set of measures and strategies implemented to detect, prevent, and mitigate fraudulent activities within an organization or system. It involves identifying fraudulent behaviors, patterns, or attempts and taking appropriate actions to safeguard against financial losses, reputational damage, and potential legal implications.
Document Verification	is a process used to authenticate and validate the authenticity of official documents presented by individuals or entities during various transactions or interactions. It involves cross-checking the information provided in the documents against reliable sources to ensure their accuracy and legitimacy. Document verification helps prevent identity fraud, forgery, and the use of counterfeit or false documents for malicious purposes.
Politically Exposed Person	is an individual who holds a prominent public position or has held such a position in the recent past, along with their immediate family members and close associates. Due to their positions, PEPs may be at a higher risk of involvement in corruption, bribery, or money laundering. Financial institutions and other regulated entities conduct enhanced due diligence on PEPs to mitigate potential risks.
Ultimate Beneficial Owner	refers to the natural person(s) who ultimately owns or controls a legal entity, directly or indirectly. Identifying the UBO is essential in AML procedures, as it helps to determine the true ownership and control structure of a business entity, which may be relevant in assessing money laundering and terrorist financing risks.
Suspicious Activity Report	is filed by financial institutions to report suspicious activities or transactions that are suspected to be linked to money laundering or other illicit activities. SARs are submitted to the appropriate authorities for further investigation
Currency Transaction Report	is a report filed with the financial intelligence unit or regulatory authority when a financial institution processes a cash transaction in excess of a certain threshold. CTRs help monitor large cash movements and detect potential money laundering activities.
Digital identity verification	utilizes advanced technology and data sources to verify the identity of customers remotely. It involves verifying official documents, conducting biometric checks, and leveraging artificial intelligence and machine learning algorithms to detect potential fraud.

 

• USER SIGN-UP. 

 

1.1. The Platform shall perform a risk assessment on the email addresses provided by users during the sign-up process to determine the likelihood of fraudulent or malicious activities.

1.2. The Sign-Up Email Risk Assessment process may involve the use of automated tools and algorithms to analyze and evaluate email addresses for potential risks.

1.3. The Platform reserves the right to deny sign-up or suspend accounts if the email address is deemed to pose a risk of fraudulent or malicious activities.

1.4. Users agree to provide accurate and valid email addresses during the sign-up process and understand that the Platform may verify the authenticity of the provided email address.

1.5. The Platform shall conduct a risk assessment on the phone numbers provided by users during the sign-up process to verify their authenticity and assess potential risk factors.

1.6. Users consent to the collection and analysis of their provided phone numbers for the purpose of phone risk assessment.

1.7. The Platform reserves the right to reject sign-up requests or suspend accounts if the provided phone number is determined to be suspicious, invalid, or associated with fraudulent activities.

1.8. Users agree to provide valid and functioning phone numbers during sign-up and understand that the Platform may use the provided phone number for verification purposes.

Device Intelligence:

1.9.  The Platform shall utilize device intelligence to gather and analyze information about the devices used by users during the sign-up process, including but not limited to device type, operating system, IP address, and geolocation.

1.10. Users acknowledge and consent to the collection and processing of device-related data for the purpose of device intelligence analysis.

1.11. Users agree to use only authorized and secure devices for sign-up and understand that the Platform may deny access or suspend accounts if the device is identified as posing a security risk.

 

• USER VERIFICATION. 

 

2.1. The Platform may require users to undergo ID verification as part of the sign-up process or at any stage during their use of the services.

2.2. Users agree to provide valid and authentic identification documents for verification, which may include government-issued IDs, passports, or other legally recognized documents.

2.3. The Platform will use secure and approved methods to verify the authenticity of the provided identification documents and may seek assistance from third-party verification services.

1.4. Users understand and acknowledge that failure to complete the ID verification process may result in restricted access to certain features or services of the Platform.

2.4. As part of the user verification process, the Platform may require users to undergo face match verification to ensure the person presenting the identification document is the same as shown in the document.

2.5. Users agree to submit a real-time facial image or video for face match verification, which will be compared with the photo on the provided identification document.

2.6. The Platform will use advanced facial recognition technology to perform face match verification securely and accurately.

2.7. Users understand and acknowledge that the face match verification process is essential for enhanced security and protection against identity fraud.

2.8. The Platform may request users to verify their residential or business address by providing valid and verifiable proof of address documents.

2.9. Users agree to provide utility bills, bank statements, or other legally recognized documents as proof of their address.

2.10. The Platform will use secure methods to verify the authenticity of the provided proof of address documents.

2.11. Users understand that the address verification process may be required for certain services or transactions on the Platform.

2.12. The Platform may offer doc-free verification methods, such as biometric verification or two-factor authentication, to facilitate a seamless and efficient user verification process.

2.13. Users may opt for doc-free verification if available, subject to the Platform's discretion and verification requirements.

2.14. The Platform reserves the right to request additional documentation or information from users even if they opt for doc-free verification.

2.15. Users understand that the doc-free verification process may require access to certain device features, such as a camera or fingerprint scanner.

2.16. The Platform shall conduct blocklist checks to verify users against known databases of individuals or entities associated with illegal or prohibited activities.

2.17. Users consent to be subject to blocklist checks as part of the user verification process.

If a user is identified in a blocklist check, the Platform may take appropriate actions, including account suspension or denial of services.

 

3. FRAUD PREVENTION. 

 

3.1. The Platform takes fraud prevention and detection seriously to maintain the security and integrity of its services. Users are strictly prohibited from engaging in any fraudulent activities on the Platform.

3.2. Users agree not to use any deceptive, misleading, or dishonest practices to obtain unauthorized access to the Platform, manipulate services, or exploit any vulnerabilities in the system.

3.3. Any attempt to deceive, misrepresent, or defraud the Platform, other users, or any third parties will be considered a breach of this agreement and may result in immediate suspension or termination of the user's account, as well as potential legal action.

3.4. Fraudulent activities include but are not limited to:

1. a) Providing false or misleading information during the verification process.
2. b) Attempting to access or use another user's account without proper authorization.
3. c) Initiating transactions with the intention of reversing or canceling them after gaining benefits.
4. d) Using stolen or unauthorized payment methods to make transactions.
5. e) Creating multiple accounts to gain unauthorized advantages or benefits.
6. f) Colluding with other users to manipulate the Platform's services or rankings.

3.5. The Platform employs various fraud detection mechanisms, including but not limited to AI-driven algorithms, user behavior analysis, and IP tracking, to identify and prevent fraudulent activities.

 

3.6. Users acknowledge that any suspicious or fraudulent activities detected by the Platform may be reported to the appropriate authorities and may result in criminal investigations and legal consequences.

3.7. The Platform reserves the right to freeze or withhold funds, delay transactions, or take any other necessary actions to investigate and prevent potential fraud.

3.8. Users are encouraged to report any suspicious activities or potential fraud to the Platform's customer support team immediately.

3.9. The Platform shall not be liable for any losses or damages incurred by users or third parties as a result of fraudulent activities conducted by other users on the Platform.

3.10. Users agree to cooperate fully with the Platform's fraud prevention and investigation efforts and provide any requested information or documentation to resolve fraud-related issues.

3.11. The Platform reserves the right to amend or update the Fraud Clause as necessary to enhance fraud prevention measures and adapt to changing fraud patterns. Any such updates will be communicated to users through the Platform's official communication channels.

 

4. CRYPTOCURRENCY WALLET USAGE.

 

4.1. The Platform provides users with access to a cryptocurrency wallet that allows them to store, send, and receive various cryptocurrencies.

4.2. Users are solely responsible for the security of their cryptocurrency wallet and the protection of their private keys. The Platform shall not be liable for any losses or damages arising from the unauthorized access to the user's cryptocurrency wallet or the misuse of their private keys.

4.3. Users must ensure that they have a clear understanding of how cryptocurrency wallets work and the risks associated with cryptocurrency transactions. The Platform shall not be responsible for any user errors or mistakes made during cryptocurrency transactions.

4.4. The Platform may impose transaction limits, fees, or other restrictions on the use of the cryptocurrency wallet. Users will be informed of any such limitations through the Platform's official communication channels.

4.5. The Platform may suspend or terminate a user's access to the cryptocurrency wallet in case of suspected fraudulent or unauthorized activities, or if the user violates the Platform's terms and conditions.

4.6. Users must not use the cryptocurrency wallet for any illegal or prohibited activities, including but not limited to money laundering, fraud, or financing of terrorism. The Platform reserves the right to report suspicious activities to the relevant authorities.

4.7. The cryptocurrency wallet is provided "as is" without any warranties, express or implied. The Platform does not guarantee the availability, accuracy, or security of the cryptocurrency wallet and shall not be liable for any interruptions or errors in its operation.

4.8. Users are responsible for keeping their cryptocurrency wallet information, including wallet addresses, private keys, and recovery phrases, confidential and secure. The Platform shall not be liable for any losses or damages resulting from the user's failure to protect their wallet information.

4.9. The Platform may add or remove supported cryptocurrencies from the wallet at its sole discretion. Users will be notified of any changes to the supported cryptocurrencies through the Platform's official communication channels.

4.10. The Platform may update or modify the features and functionalities of the cryptocurrency wallet from time to time. Users will be informed of any significant changes through the Platform's official communication channels.

4.11. Users may not use the cryptocurrency wallet to conduct transactions that violate the laws and regulations of their jurisdiction or the jurisdiction where the Platform operates.

4.12. The Platform reserves the right to suspend or terminate the cryptocurrency wallet service at any time, with or without notice, at its sole discretion.

4.13. By using the cryptocurrency wallet, users agree to comply with these terms of usage and the overall terms and conditions of the Platform. Failure to comply may result in the termination of access to the cryptocurrency wallet and other Platform services.

4.14. The Platform shall not be liable for any third-party services or products accessed through the cryptocurrency wallet. Users are encouraged to exercise caution and conduct their due diligence before using any third-party services.

4.15. Any issues or concerns related to the cryptocurrency wallet should be directed to the Platform's customer support team for assistance.

 

5. LIMITATIONS.

 

5.1. The Platform reserves the right to limit, at its sole discretion, any aspect of its services, including but not limited to transaction volume, account balance, investment options, withdrawal limits, and access to certain features or functionalities.

5.2. Users acknowledge that the Platform's limitations are implemented to ensure compliance with legal and regulatory requirements, maintain the security of user accounts and funds, prevent fraudulent activities, and promote fair usage of the Platform's services.

5.3. The Platform may impose temporary or permanent restrictions on specific services or features based on factors such as user behavior, risk assessment, compliance with policies, or changes in regulatory requirements.

5.4. The Platform may apply fees, charges, or other costs for certain transactions or services, and users will be informed of any applicable fees through the Platform's official channels.

 

6. CONCLUSIONS. 

 

6.1. By using the Platform and its services, you acknowledge that you have read, understood, and agree to comply with the provisions of this AML Policy. You further affirm that all information provided by you during the sign-up process and in the course of using the Platform's services is true, accurate, and complete to the best of your knowledge.

6.2. You agree to cooperate fully with the Platform's efforts to comply with all applicable AML and KYC regulations and requirements. This includes providing any additional information or documentation as may be requested by the Platform to verify your identity and conduct due diligence.

6.3. If you become aware of or suspect any suspicious or potentially fraudulent activity on the Platform, including but not limited to money laundering or terrorist financing, you must immediately report such activity to the Platform. The Platform takes the detection and reporting of suspicious activity seriously and is committed to maintaining a safe and secure environment for all users.

6.4. The Platform reserves the right to modify, update, or amend this AML Policy at any time, in its sole discretion. Any changes to this AML Policy will be posted on the Platform's website, and it is your responsibility to review such changes periodically. Your continued use of the Platform after the posting of any changes to this AML Policy constitutes your acceptance of such changes.