– Anti-Money Laundering and Counter Terrorism Financing Policy

When using our website or platform you agree to abide by this policy.

Anti-Money Laundering and Counter Terrorism Financing Policy

1. Introduction

This Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy (“Policy”) outlines the measures and procedures adopted by Blockifi Inc. (“Company”) to prevent money laundering and the financing of terrorism through its services. The Company is committed to adhering to all applicable laws and regulations related to AML and CTF, and to maintaining the integrity of its financial systems and services.

2. Purpose

The purpose of this Policy is to establish a framework for identifying, assessing, and mitigating the risks associated with money laundering and terrorist financing. This Policy aims to ensure compliance with all relevant laws, regulations, and guidelines, and to protect the Company from being used as a conduit for illegal activities.

3. Risk Assessment

The Company will conduct regular risk assessments to identify and evaluate potential AML and CTF risks associated with its services, clients, and business relationships. This assessment will consider factors such as transaction volume, geographical locations, client profiles, and emerging industry trends.

4. Customer Due Diligence (CDD)

The Company will implement thorough customer due diligence procedures during onboarding and throughout the client relationship. This will include the collection and verification of customer information, identification of beneficial owners, and assessment of the customer’s risk profile. Enhanced due diligence will be applied to high-risk clients, ensuring a deeper understanding of their activities and sources of funds.

5. Monitoring and Reporting

The Company will monitor transactions for suspicious activities, including large or complex transactions, unusual patterns, and high-risk clients. Any suspicious activity will be reported to the relevant authorities in accordance with applicable laws and regulations. The Company will maintain records of such reports and related documentation.

6. Training and Awareness

All employees will receive regular training on AML and CTF procedures, regulations, and the identification of suspicious activities. This will ensure that employees are equipped to detect and report potential instances of money laundering or terrorist financing.

7. Internal Controls

The Company will establish and maintain internal controls to prevent and detect money laundering and terrorist financing. These controls will include procedures for the identification and verification of clients, transaction monitoring, record-keeping, and reporting of suspicious activities.

8. Sanctions Screening

The Company will implement processes to screen clients, transactions, and business relationships against relevant sanctions lists and watchlists. This will help ensure compliance with international sanctions regimes and prevent dealings with individuals or entities subject to sanctions.

9. Reporting and Record Keeping

The Company will maintain accurate and up-to-date records of customer due diligence, transaction records, and AML/CTF compliance activities. These records will be retained for the duration required by applicable laws and regulations.

10. Cooperation with Authorities

The Company will collaborate fully with law enforcement agencies and regulatory authorities in their efforts to combat money laundering and terrorist financing. This includes providing information, documentation, and assistance as required by law.

11. Review and Updates

This Policy will be reviewed periodically to ensure its effectiveness and alignment with changing regulatory requirements and industry best practices. Updates will be made as necessary to address emerging risks and challenges.

12. Conclusion

This AML and CTF Policy reflects the Company’s commitment to maintaining the highest standards of integrity and compliance. By adhering to these measures and procedures, Blockifi Inc. aims to prevent money laundering and the financing of terrorism, contributing to the safety and stability of the financial system.

Date of Policy Approval: 01/31/2023

Blockifi, Inc

Contact Information: [email protected]

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