AML POLICIES AND PROCEDURES

MATTERCASH INC. has established a comprehensive Anti-Money Laundering (AML) Compliance and Supervisory Procedures document aimed at preventing money laundering and the financing of terrorist activities. This document outlines the firm's policy against these illegal acts, emphasizing the necessity for all employees to be vigilant and report suspicious activities. The policy covers the understanding of money laundering through stages such as Placement, Layering, and Integration, highlighting the importance of disguising illegal proceeds to make them appear legitimate.

A designated AML Compliance Officer, Dale Olmstead, is tasked with overseeing the firm's AML program, ensuring compliance, and filing Suspicious Activity Reports (SARs) as necessary. The document further elaborates on the firm's procedures for giving AML information to law enforcement agencies, checking government lists for sanctioned individuals or entities, and adhering to customer identification and verification processes to prevent misuse of the financial system.

The procedures detail steps for monitoring accounts for suspicious activities, identifying "red flags," and the importance of employee training in recognizing and reporting money laundering activities. The document also outlines the requirements for reporting certain transactions, like Currency Transaction Reports (CTR) and SARs for Money Service Businesses (SAR-MSB), to appropriate regulatory bodies.

Additional aspects covered include the management of employee backgrounds to prevent insider involvement in illicit activities, the process for handling suspicious transactions and BSA reporting, and specific policies related to the purchase, repurchase, and transfer of precious metals. The document emphasizes the importance of AML recordkeeping, confidential reporting of AML non-compliance, and outlines the firm's vault program for secure storage services.

The concluding sections reaffirm MATTERCASH INC.'s commitment to AML compliance through the approval of these procedures by the senior manager, Dale Glenn Olmstead, CEO, underscoring the legal and ethical obligations to combat money laundering and terrorist financing within their operations.

For the full Anti-Money Laundering Compliance and Supervisory Procedures click here.