AFROEXPRESSPAY AML & COMPLIANCE POLICY



Softiva Corp. ("AfroExpressPay") is licensed as a money transmitter by the department of financial services of the following state: NJ. We are also a registered money service business with the Financial Crimes Enforcement Network (FinCEN). It is always our policy to comply with all government regulations. As a money service business, we are subject to the following regulations:

Reporting

We are required to report the following types of transactions to the authorities:

  • Suspicious Activity

  • Large Currency Transactions

Record Keeping

We are required to keep all customer ID, transaction, and corporate records for a minimum of 5 years.

Ascertaining Identity

We are required to collect and verify your identification for remittances of $3,000 and more.

Politically Exposed Person (PEP)

We are required to make PEP determination for transactions that have any ties to politically exposed persons.

Third Party Determination

If you are conducting a transaction on someone else's behalf, we are required to obtain information on both parties; you and the person on whose behalf you are conducting the transaction.

Compliance Program

We are required to maintain a compliance program containing adequate policies and procedures in accordance with the applicable regulations.

For more information, refer to FINCEN Website:

http://www.fincen.gov/financial_institutions/msb/

WE TAKE THE FOLLOWING ADDITIONAL MEASURES TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING:

Scanning Against the OFAC List

It is our policy to check each transaction against the OFAC list. Any matched names are subject to further review by the compliance officer.

Transaction Monitoring

We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:

  • Client Profiling

  • Risk Assessment

  • Client Identification Controls & Validations

  • Transaction Aggregation Thresholds

  • Government Reporting Controls & Validations

  • Possible Structuring Reporting

  • Enhanced Due Diligence Reporting