SaveCash is committed to preventing money laundering, terrorist financing, and other financial crimes. This Know Your Customer ("KYC") and Anti-Money Laundering ("AML") Policy establishes our procedures for verifying user identities, monitoring transactions, and complying with applicable regulations including the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and international AML standards.

1. KYC Procedures

1.1 Identity Verification

Prior to account activation, all users must undergo identity verification:

• Government-issued identification: Valid driver's license, passport, or state-issued ID card with photo
• Address verification: Utility bills, bank statements, or government correspondence not older than 90 days
• Date of birth verification: Official documents confirming date of birth
• Social Security Number (SSN) or Tax ID: For US residents and businesses
• Liveness detection: Biometric verification using facial recognition and document authenticity checks
• Email and phone verification: Confirmed contact information with active verification codes

1.2 Enhanced Due Diligence (EDD)

Enhanced verification procedures apply to:

• Politically Exposed Persons (PEPs) and their close associates
• Individuals from high-risk jurisdictions designated by FATF or OFAC
• Businesses operating in cash-intensive or high-risk industries
• Transactions exceeding regulatory thresholds ($3,000 per transaction, $10,000 cumulative monthly)
• Any activity that triggers our automated risk scoring system
• Corporate accounts and beneficial ownership structures

1.3 Ongoing Monitoring

We continuously monitor accounts for suspicious activities including:

• Unusual transaction patterns or velocity changes
• Transactions to high-risk jurisdictions or sanctioned entities
• Potential structuring to avoid reporting thresholds
• Account relationships with sanctioned individuals or entities
• Changes in account behavior or user profile information
• Multiple accounts linked to the same individual or device

2. AML Compliance

2.1 Suspicious Activity Reporting

SaveCash will be required by law to file Suspicious Activity Reports (SARs) with FinCEN when we detect potentially suspicious transactions. We are committed to maintaining robust SAR filing procedures:

• Automated detection systems analyzing millions of transaction patterns in real-time
• Manual review by trained compliance analysts and AML specialists
• Documentation and investigation of all flagged activities
• Filing SARs within required timeframes (no later than 30 days after detection)
• Extension requests filed when complex investigations require additional time
• Strict confidentiality and prohibited tipping off subjects of investigations

2.2 Currency Transaction Reports (CTRs)

We file CTRs for transactions exceeding $10,000 in value and monitor for patterns indicating structuring or smurfing.

2.3 OFAC Sanctions Screening

All users and transactions are screened against Office of Foreign Assets Control (OFAC) sanctions lists and other government watchlists. We maintain a zero-tolerance policy for interactions with sanctioned entities and will immediately freeze or close accounts identified on sanctions lists.

3. Risk-Based Approach

SaveCash employs a comprehensive risk-based approach to compliance, categorizing users into risk tiers and applying proportional controls:

• Low Risk: Standard KYC procedures, periodic reviews every 24-36 months
• Medium Risk: Enhanced verification, annual reviews, additional transaction monitoring
• High Risk: Continuous monitoring, quarterly reviews, mandatory senior management approval for any account changes
• Prohibited: Immediate account closure and reporting to authorities

4. Customer Due Diligence Requirements

For business accounts, we require:

• Business registration documents and incorporation certificates
• Articles of incorporation, operating agreements, or partnership agreements
• Tax identification numbers and business licenses
• Beneficial ownership information for all owners with 25% or more equity
• Identity verification for all authorized signatories and account administrators
• Ultimate beneficial owner (UBO) identification for complex corporate structures
• Proof of business address and physical premises
• Business purpose and expected transaction volumes

5. Recordkeeping and Data Retention

We are committed to maintaining comprehensive records of:

• All KYC documentation and identity verification records for 5 years after account closure
• Transaction records for 5 years from transaction date, as required by BSA
• SAR filings and supporting documentation for 5 years from filing date
• Suspicious activity investigation files for regulatory compliance and audit purposes
• Training records and certifications for compliance personnel

6. Sanctions Compliance

SaveCash is committed to strictly complying with all applicable sanctions programs administered by OFAC, the United Nations, the European Union, and other relevant authorities. We will:

• Screen all users against sanctions lists during onboarding and continuously thereafter
• Block transactions to or from sanctioned jurisdictions or entities
• Maintain restricted party screening databases updated daily
• Immediately freeze assets and close accounts of sanctioned individuals or entities
• Report violations to appropriate regulatory authorities
• Conduct regular sanctions compliance training for all personnel

7. Compliance Training and Testing

SaveCash is committed to maintaining a robust compliance training program:

• Mandatory annual AML training for all employees
• Role-specific training for compliance, operations, and customer service personnel
• Ongoing updates on emerging money laundering typologies and regulatory changes
• Third-party compliance assessments and external audits
• Independent testing of AML systems and controls
• Management oversight and board-level governance

8. Regulatory Cooperation

SaveCash cooperates fully with law enforcement, regulatory authorities, and financial intelligence units. We respond promptly to information requests, subpoenas, and regulatory examinations while maintaining appropriate confidentiality protocols.

9. User Obligations

Users must:

• Provide accurate, complete, and current information during account registration and verification
• Promptly update any changes to personal or business information
• Not use SaveCash services for any illegal or fraudulent purpose
• Cooperate with any requests for additional information or documentation
• Understand that we may suspend or close accounts that fail verification or exhibit suspicious behavior

10. Contact Information

For questions about our KYC/AML compliance or to report suspicious activity: