Anti-Money Laundering Policy

1. Policy Overview

AOBOOT is committed to maintaining the integrity of the financial system and preventing our services from being used for money laundering or terrorist financing activities. This Anti-Money Laundering (AML) policy follows international AML standards and best practices.

2. Applicable Laws and Regulations

Our AML policy complies with the following laws and regulations:

• Financial Action Task Force (FATF) Recommendations
• U.S. Bank Secrecy Act (BSA)
• U.S. Patriot Act
• EU Fourth and Fifth Anti-Money Laundering Directives
• Local AML regulations in various jurisdictions

3. Customer Identification (KYC)

We implement strict customer identification procedures:

• Require government-issued identification documents
• Verify name, date of birth, and address information
• Collect and verify business nature and purpose
• Identify and verify beneficial owners
• Continuously monitor changes in customer identity information

4. Customer Due Diligence (CDD)

We conduct customer due diligence based on risk level:

• Standard Due Diligence: For low-risk customers
• Enhanced Due Diligence (EDD): For high-risk customers
• Simplified Due Diligence (SDD): For specific low-risk situations
• Regular review and update of customer information

5. High-Risk Customer Identification

The following types of customers are considered high-risk:

• Politically Exposed Persons (PEPs)
• Customers from high-risk countries or regions
• Cash-intensive businesses
• Complex corporate structures or offshore entities
• Customers with unusual or unreasonable transaction patterns

6. Transaction Monitoring

We implement a comprehensive transaction monitoring system:

• Real-time transaction monitoring and analysis
• Identify unusual or suspicious transaction patterns
• Set appropriate transaction limits
• Automatically flag high-risk transactions
• Regularly review transaction activity reports

7. Suspicious Activity Reporting

For suspicious transactions, we will:

• Promptly report suspicious activities to relevant regulatory authorities
• Retain all transaction records and related documents
• Not disclose submitted suspicious activity reports to customers
• Cooperate with law enforcement investigations

8. Sanctions Screening

We screen all customers and transactions against sanctions lists:

• Screen against OFAC sanctions lists
• Screen against UN sanctions lists
• Screen against EU sanctions lists
• Screen against other relevant sanctions and watchlists
• Real-time updates to sanctions list databases

9. Record Retention

We retain the following records for at least 5 years:

• Customer identification documents
• Transaction records and account files
• Due diligence documentation
• Copies of suspicious activity reports
• Communications records with customers

10. Employee Training

We provide AML training to all employees:

• Regular AML and counter-terrorist financing training
• Training on latest regulatory requirements and best practices
• Training on how to identify and report suspicious activities
• Maintain training records and certificates

11. Third-Party Relationships

For partnerships with third parties, we will:

• Conduct comprehensive due diligence
• Ensure third parties comply with AML requirements
• Regularly review third-party compliance status
• Include AML clauses in contracts

12. Account Restrictions and Termination

We may restrict or terminate accounts in the following circumstances:

• Customer refuses to provide required identity information
• Discovery of false or misleading information
• Customer is listed on sanctions lists
• Detection of suspicious or illegal activities
• Violation of our Terms of Service

13. Policy Review

We regularly review and update this policy to ensure compliance with the latest laws, regulations, and industry best practices.

14. Reporting Suspicious Activities

If you discover any suspicious activities, please contact us through:

• Email: compliance@aoboot.com
• Compliance Hotline: Submit confidential reports through the platform