Money Laundering (AML) Policy
MyBillions is committed to combating money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our approach to identifying, preventing, and mitigating risks associated with money laundering and terrorist financing activities. We adhere to all applicable laws, regulations, and industry best practices to maintain the integrity of our platform and protect the interests of our users.
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**2. Compliance Responsibilities**
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2.1 Compliance Officer: We designate Mr Prashant Raghuwanshi as the Compliance Officer responsible for overseeing the implementation and enforcement of this AML Policy. The Compliance Officer ensures that our policies, procedures, and controls are adequate, effective, and up-to-date.
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2.2 Employee Training: We provide regular training and education to our employees to raise awareness of AML risks and requirements. Employees receive training on identifying suspicious activities, conducting customer due diligence (CDD), and reporting suspicious transactions.
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2.3 Customer Due Diligence (CDD): We conduct thorough due diligence on our customers to verify their identities, assess their risk profiles, and monitor their transactions for unusual or suspicious behaviour. Enhanced due diligence (EDD) measures are applied to high-risk customers and transactions.
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2.4 Transaction Monitoring: We implement robust transaction monitoring systems and procedures to detect and investigate potentially suspicious transactions. We monitor transaction patterns, volumes, and other relevant factors to identify unusual or suspicious activities.
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**3. Customer Identification and Verification**
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3.1 Know Your Customer (KYC): We collect and verify customer information as part of our KYC process to establish the identity of our customers and assess their risk levels. We obtain relevant identification documents and conduct identity verification checks using reliable and independent sources.
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3.2 Enhanced Due Diligence (EDD): We perform enhanced due diligence on customers and transactions that pose higher AML risks, including politically exposed persons (PEPs), high-net-worth individuals (HNWIs), and customers from high-risk jurisdictions. EDD measures may include additional identity verification, source of funds analysis, and ongoing monitoring.
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3.3 Third-Party Relationships: We conduct due diligence on third-party service providers, partners, and intermediaries to assess their AML controls and integrity. We only engage with reputable and compliant entities that adhere to applicable AML regulations and standards.
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**4. Reporting and Compliance Monitoring**
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4.1 Suspicious Activity Reporting: We maintain procedures for reporting suspicious activities to the relevant authorities, such as financial intelligence units (FIUs) or law enforcement agencies. Our employees are trained to recognize red flags and indicators of money laundering or terrorist financing and escalate suspicious activities for further investigation.
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4.2 Compliance Monitoring: We conduct periodic reviews and audits of our AML program to assess its effectiveness and compliance with regulatory requirements. We review our policies, procedures, and controls regularly to identify areas for improvement and address emerging risks.
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**5. Recordkeeping and Documentation**
5.1 Record Retention: We maintain accurate and up-to-date records of customer information, transactions, and AML activities in accordance with regulatory requirements. Records are retained for the prescribed retention periods and are accessible for regulatory examinations and investigations.
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5.2 Documentation: We document our AML policies, procedures, risk assessments, and compliance efforts to demonstrate our commitment to AML compliance. Documentation is regularly reviewed, updated, and communicated to relevant stakeholders.
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**6. Compliance with Laws and Regulations**
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6.1 Legal and Regulatory Compliance: We comply with all applicable AML laws, regulations, and guidelines issued by regulatory authorities in the jurisdictions where we operate. We stay informed about changes in AML requirements and update our policies and procedures accordingly.
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6.2 Reporting Obligations: We fulfil our reporting obligations to regulatory authorities, including filing suspicious activity reports (SARs) and other required disclosures. We cooperate with law enforcement agencies and regulatory authorities in investigations related to money laundering or terrorist financing activities.



