Anti Money Laundering Policy

All STI executives, staff members, authorized partners, and services are subject to this policy. STI business operations and offices would work together to develop a coordinated strategy to combat financial fraud. Every business entity has put in place uncertainty policies that should be able to stop, catch, and make transactions reportable. Every integrated effort will be recorded and kept. Mandatory reporting to the relevant enforcement agencies or governing bodies must be started.

A representative must:
  • Obtain statements from corporate money-laundering investigations.
  • Investigate rumors of illegal activity.
  • Report any unusual behavior to the appropriate agencies.
  • Make sure that the plans developed for the education and training of the personnel and advisors are adequate.
  • Annually report to the company's regulatory body on the effectiveness of the company's procedures and regulations.
  • Keep a close eye on how anti-money laundering measures are being implemented on a daily basis in connection to the production of new goods, the hiring of potential clients, and adjustments to the company's clientele.
STI policy is to aggressively work against financial fraud and any practice that aids or supports the support of terrorism as well as other illegal conduct. STI demands that all of its executives, staff, and authorized professionals abide by all of these criteria. For such objectives, money laundering is widely understood to mean taking actions intended to hide or distort the reasons for earnings obtained through illegal activity, such that the illicit earnings might seem to have come from legal sources or to be genuine holdings. The procedure of exchanging "dirty" income or even other properties without a clear connection to its illicit sources in terms of money or its equivalent, securities, tangible items, and intangible assets are all examples of criminal property. It also includes any kind of funding used to support terrorism.

Money-laundering practices consist of:
  • Illegal asset possession, use, or acquisition.
  • Managing ill-gotten gains obtained through robbery, forgery, and tax evasion.
  • Becoming intentionally associated with illegal or terrorist assets in any way.
  • Forming agreements to facilitate the transfer of illicit or terrorist assets.
  • Incorporating money obtained through theft into other financial statements.
  • Purchasing real estate or assets with the intention of investing illicit earnings.
Criminal Property Transfer
Money laundering is a process that includes many stages, from the buying and selling of expensive goods like gold or automobiles, through the passage of funds via a convoluted network of legal business ventures. Cash will typically be the beginning point, but it really is crucial to know that money laundering is characterized in terms of illicit assets. If you know or suspect that it was obtained illegally, either directly or indirectly, and you remain silent, you are also participating in the crime.

Can we counter terrorist financing?
The practice of lawful companies and individuals choosing to support terrorist organizations or actions for philosophical, social, or other motives is known as "terrorist financing". Consequently, businesses need to ensure that their clients are not terrorist organizations. Attempts to hide the source or planned utilization of cash that may later be utilized for illegal activities constitute terrorist funding and may not entail the earnings of criminality.

Risk-Based Methodology
Risk-based thinking can guide the degree of attention needed when evaluating anti-money laundering practices within a company.

User Risk
Risks are associated with distinct consumer profiles to varying degrees. The risk assumed by a consumer can be determined by performing a simple Know Your Customer (KYC) examination. A person making sporadic payments of ever-changing proportions into a savings account that does not suit the customer’s existing financial data is risky.

Product Safety
Product risk is posed by the actual good or service. The product's usefulness as a tool for money laundering drives the risk associated with it.

Danger: Geographical Location
Due to the fact that different nations throughout the world have varying degrees of risk associated with them, the country of the user or the economic activity has a certain amount of risk. SafeTrust Innovations will notify customers of the request for their identity information; they will then gather each user's identifying data and store it alongside with the user’s verification processes and outcomes. The organization must understand the type of business service a user anticipates when building business relationships in order to determine what routine activity will be created in the partnership. Any consistent business transactions done for a user after an established commercial connection will be evaluated in light of the user's expected pattern of activity. However, if such a user is charged with money laundering, then the expected pattern of the user’s will be broken. Details on the user’s earnings, job, origin of wealth, trade preferences, and the economic motive for any transaction are exclusively required. At the beginning of the business, users' details like their nationality, birthdate, and state of residence are also gathered. Verification of the user’s information is indeed important and necessary when taking an extremely high risk.

The Origin of Funds
The means or method by which payments are paid, from the sender to the beneficiary, and to whom they are being sent to, must always be determined and documented in the user records whenever a transaction occurs.

Identification requirement
The following details are needed for STI identification processes and for assets with reduced risk.
  1. The user's name.
  2. Place of residence.
  3. Government-issued documents with the user’s photographs.
  4. A current photo passport.
  5. National identification document.
Verification of user’s information
User’s information collected must be based on trustworthy and impartial sources, which may be transferred to us via user’s documents or be collected electronically. Because there is a higher possibility that the authorities have verified the existence and features of the supposed user in question, data proving a user's identity that can be trusted to be that person is often confirmed by a government agency. In a situation where users have no required documents backed by a government agency, the company is set to list out other documents that users may see as alternatives. However, the firm should assess these alternatives against the associated dangers.
If a user’s identification can be confirmed through documentation, the following criteria should be used:
It must be a document published by the government that contains:
  • The user's full name.
  • Place of residence.
  • government-issued documents with the user’s photographs.
  • A current photo passport.
  • National identification document.
Suspicious User Behavior
Indications of questionable behavior that point to money laundering must be addressed by the appropriate authorities. These activities may include:
  • The user wants to enter into transactions that either go against their stated business plan or their apparent investing strategy.
  • The user has submitted fraudulent, deceptive, or significantly inaccurate information.
  • The user fails to disclose any legitimate sources of funds or other assets.
  • The customer has a dubious history or is the focus of press reports indicating potential civil, criminal, or regulatory infractions.
  • The user appears to be acting as an agent for an unnamed principal but refuses to reveal any information about that principal or is otherwise evasive about it for no apparent reason.
  • The user finds it difficult to describe the nature of their company or lacks a general understanding of their sector.
  • The user tries to deposit significant amounts of money frequently, insists on only transacting in cash equivalents, or requests an exception to the firm's rules regarding the deposit of cash and cash equivalents.
  • The user has numerous accounts under one or more names for no discernible purpose, and there are a lot of transfers from one account to another or to third parties.
  • The user's account experiences unexpected or unexplained extensive activity, particularly in accounts with little or no prior activity.
  • There are several wire transfers to unrelated third parties on the customer's account, which is incongruous with the user's lawful business purpose.
  • The user's account shows significant or repeated wire transfers that were promptly withdrawn by cheque or debit card without seeming to serve any commercial purpose.
  • The user deposits money and then requests, without clear business justification, that it be wired out to a third party or moved to another company.
  • The user deposits funds with the intention of purchasing a long-term investment; however, the customer soon requests that the investment be liquidated and the proceeds transferred out of the account.
  • The user requests that a transaction be performed without the usual paperwork requirements of the company. A transaction that is incongruous with a user's recognized typical transactions for that sort of user is frequently regarded as suspicious. When deciding if a transaction from an established user might be suspicious, you must take into account the following:
    • Are the transactions in accordance with the user's typical business behavior?
    • In the context of the user's professional or private activities, is the transaction reasonable?
    • Has the user's usual pattern of transactions changed?

    • When the size of the available funds doesn't seem to fit with the user's other pattern (where the source of wealth is unclear).
    • Where the purchase seems illogical when viewed in light of the user's professional or private activities Particular caution should be exercised in this area if the user modifies how they communicate with you without providing a plausible justification.
    • When the transactional pattern deviates.
    • When a user conducts foreign transactions but appears to have no justification with the countries involved.
    • Users who refuse to provide standard personal or financial information for no obvious or logical reason.
    • Users must immediately report in writing any suspicion that a user they are representing is engaging in (or attempting to engage in) a transaction involving the proceeds of any crime.

    Accounts Suspension
    The account must be frozen if we have reason to believe that the funds in it are the result of fraud or criminal conduct. The account may need to be frozen if it is thought that the account holder may be connected to the fraudulent conduct that is being reported.

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