Anti-Money Laundering (AML) Policy

Truehub is committed to:

• Preventing criminal elements from using our platform for money laundering or terrorist financing
• Complying with all applicable AML/CTF laws and regulations
• Cooperating fully with law enforcement and regulatory authorities
• Maintaining robust internal controls and procedures
• Training our staff to recognize and report suspicious activities
• Conducting regular reviews and audits of our AML program

2.1 Customer Identification Program (CIP)

We verify the identity of all customers through:

• Collection of full legal name, date of birth, and address
• Government-issued photo ID verification (passport, driver's license, national ID)
• Proof of address documentation (utility bill, bank statement)
• Facial recognition or video verification where applicable
• Tax identification number or equivalent

2.2 Enhanced Due Diligence (EDD)

For high-risk customers, we conduct additional verification including:

• Source of wealth and funds documentation
• Employment or business verification
• Purpose and nature of business relationship
• Expected transaction volume and patterns
• Politically Exposed Person (PEP) screening
• Adverse media checks

2.3 Ongoing Monitoring

• Regular updates of customer information
• Periodic review of customer risk ratings
• Continuous transaction monitoring
• Annual KYC refresh for active accounts

3.1 Customer Risk Categories

We categorize customers based on risk factors:

3.2 Geographic Risk

We assess geographic risk based on:

• FATF high-risk and monitored jurisdictions
• Countries subject to sanctions
• Corruption perception index
• AML/CTF regime effectiveness

4.1 Automated Monitoring Systems

Our systems monitor for:

• Unusual transaction patterns or volumes
• Rapid movement of funds
• Transactions just below reporting thresholds (structuring)
• Multiple accounts with similar details
• Dormant account sudden activity
• Geographic anomalies

4.2 Red Flags

Indicators that trigger enhanced scrutiny:

• Reluctance to provide KYC information
• Inconsistent or suspicious documentation
• Unusual source of funds explanations
• Requests to expedite transactions without clear reason
• Multiple small deposits followed by large withdrawal
• Use of multiple payment methods
• Transactions inconsistent with customer profile

4.3 Investigation Process

• Immediate flag of suspicious transactions
• Investigation by compliance team
• Request for additional information from customer
• Decision on transaction approval or rejection
• Documentation of investigation findings

5.1 Sanctions Lists Checked

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Sanctions List
• EU Consolidated Sanctions List
• HM Treasury Sanctions List
• Local jurisdiction sanctions lists

5.2 PEP Screening

• Identification of Politically Exposed Persons
• Family members and close associates of PEPs
• Enhanced due diligence for PEP accounts
• Senior management approval for PEP relationships
• Ongoing enhanced monitoring

5.3 Screening Frequency

• Real-time screening at onboarding
• Daily batch screening of existing customers
• Real-time transaction screening
• Immediate action on positive matches

6.1 Suspicious Activity Reports (SARs)

We file SARs when we detect:

• Transactions involving $5,000 or more with suspected illegal activity
• Transactions designed to evade BSA requirements
• No business or apparent lawful purpose
• Unusual patterns for the customer
• Use of the platform to facilitate criminal activity

6.2 Currency Transaction Reports (CTRs)

• Filed for cash transactions exceeding $10,000
• Aggregated transactions by same person in one day
• Maintained for regulatory review

6.3 Regulatory Cooperation

• Full cooperation with law enforcement requests
• Response to subpoenas and court orders
• Proactive reporting of criminal activities
• Participation in information sharing programs

We maintain comprehensive records including:

• Customer identification documents - 5 years after account closure
• Transaction records - 5 years from transaction date
• SAR and CTR filings - 5 years from filing
• Account opening records - 5 years after closure
• Correspondence related to compliance - 5 years
• Training records - 5 years
• Risk assessments and reviews - 5 years

Our comprehensive training program includes:

• Initial AML training for all new employees
• Annual refresher training for all staff
• Role-specific training for compliance personnel
• Updates on regulatory changes
• Case studies and practical scenarios
• Testing and certification requirements
• Documentation of training completion

The following activities are strictly prohibited:

• Money laundering or attempted money laundering
• Terrorist financing or support
• Fraud or financial crimes
• Tax evasion or avoidance schemes
• Sanctions evasion
• Human trafficking proceeds
• Drug trafficking proceeds
• Corruption and bribery proceeds
• Any other illegal activities

10.1 AML Compliance Officer

• Designated officer responsible for AML program
• Direct reporting to senior management
• Authority to implement controls
• Regular updates to board of directors

10.2 Internal Audit

• Annual independent audit of AML program
• Testing of internal controls
• Review of policies and procedures
• Recommendations for improvements

10.3 Continuous Improvement

• Regular review of AML policies
• Updates based on regulatory changes
• Implementation of new technologies
• Feedback incorporation from audits