AML Policy — BSystem

1. Policy Statement

BSystem Technologies Ltd. is committed to preventing the use of its products and services for money laundering, terrorist financing, proliferation financing, bribery, corruption, tax evasion, fraud, and sanctions evasion.

This policy applies to all employees, officers, directors, contractors, and agents of BSystem, as well as all products, services, and customer relationships across all jurisdictions in which we operate.

2. Customer Due Diligence (CDD)

We apply a risk-based approach to customer due diligence, with three tiers of verification:

Simplified Due Diligence (SDD)

Applied to lower-risk customers and relationships where:

The customer is a publicly listed company subject to regulatory disclosure requirements
The product has reduced functionality (e.g., low-value prepaid accounts with spend limits)

Standard Due Diligence

Applied to all customers at onboarding, including:

Identity verification using government-issued documents
Address verification through utility bills or bank statements
Screening against PEP, sanctions, and adverse media databases
Source of funds assessment for initial deposits

Enhanced Due Diligence (EDD)

Applied to higher-risk customers and situations, including:

Politically Exposed Persons (PEPs) and their close associates
Customers from high-risk jurisdictions (FATF grey/black list)
Complex ownership structures or trusts
Unusual or large transactions inconsistent with the customer's profile
Correspondent banking relationships

3. Transaction Monitoring

We operate a comprehensive transaction monitoring programme that includes:

Real-Time Screening

All transactions are screened in real-time against sanctions lists (OFAC SDN, HMT, EU, UN) and internal watchlists.

Anomaly Detection

Machine learning models analyse transaction patterns to identify unusual behaviour, structuring, and potential layering activity.

Threshold Reporting

Automatic generation of Currency Transaction Reports (CTRs) for cash transactions over $10,000 (US) / Large Cash Transaction Reports over CAD $10,000 (Canada).

Ongoing Monitoring

Continuous customer risk reassessment through periodic reviews, with frequency determined by customer risk rating (high: annual, medium: biennial, low: triennial).

4. Suspicious Activity Reporting

When suspicious activity is identified, we follow a structured reporting process:

1

Detection

Automated systems or staff identify potentially suspicious activity through monitoring alerts or customer interactions.

2

Investigation

Our Financial Crime team conducts a thorough investigation, including transaction analysis, customer history review, and open-source intelligence.

3

Decision

The MLRO (Money Laundering Reporting Officer) or nominated officer determines whether a SAR/STR should be filed.

4

Filing

SARs filed with FinCEN (US), NCA via DAML (UK), or FINTRAC (Canada) within mandated timeframes.

5

Action

Appropriate action taken on the account (continued monitoring, restrictions, or closure) based on investigation findings and regulatory guidance.

Tipping Off: It is a criminal offence to inform a customer or any third party that a SAR has been filed, is being considered, or that an investigation is underway. BSystem employees are prohibited from "tipping off" under applicable laws.

5. Sanctions Compliance

BSystem maintains a comprehensive sanctions compliance programme that includes:

Real-time screening of all customers and transactions against OFAC (US), HMT (UK), OSFI (Canada), EU, and UN sanctions lists
Screening against sectoral sanctions and country-specific embargo programmes
Automated blocking and rejection of transactions involving sanctioned parties
Regular updates to screening databases (within 24 hours of list publication)
Manual review and escalation process for potential false positives
Prohibition on processing transactions involving comprehensively sanctioned countries

6. Risk Assessment

We conduct a comprehensive, enterprise-wide AML/CTF risk assessment at least annually, evaluating risks across the following dimensions:

Customer Risk

Customer type, occupation, source of wealth, PEP status, geographical location, and nature of business relationship.

Product/Service Risk

Anonymity potential, transaction speed, cross-border capability, cash intensity, and new product vulnerabilities.

Geographic Risk

FATF mutual evaluation results, Transparency International CPI, sanctions exposure, and political stability.

Channel Risk

Non-face-to-face onboarding, digital channels, third-party intermediaries, and correspondent relationships.

7. Training & Awareness

All BSystem employees receive mandatory AML/CTF training:

Onboarding: Comprehensive AML awareness training within 30 days of joining
Annual Refresher: Updated training on regulatory changes, emerging typologies, and case studies
Role-Specific: Enhanced training for compliance, customer-facing, and senior management teams
Ad-hoc: Targeted training in response to emerging risks, regulatory feedback, or internal audit findings

8. Record Keeping

In accordance with regulatory requirements, we maintain records of:

Customer identification and verification documents — 5 years after the end of the relationship
Transaction records — 5-7 years from the date of the transaction (jurisdiction-dependent)
SARs and related investigation files — 5 years from the date of filing
Training records — duration of employment plus 5 years
Risk assessments and compliance reports — 5 years

9. Your Obligations

As a BSystem customer, you agree to:

Provide accurate and truthful information during onboarding and throughout the relationship
Promptly update us if any of your personal or business details change
Cooperate with any requests for additional information or documentation
Not use our services for any illegal purpose
Not allow any third party to use your account for money laundering or terrorist financing

Failure to comply may result in account restrictions, closure, and/or reporting to relevant authorities.

Contact Our Compliance Team

BSystem Technologies Ltd.

Chief Compliance Officer / MLRO

Email: compliance@bsystem.com

Phone: +1 (800) 555-0199

To report suspicious activity: suspicious@bsystem.com

Anti-Money Laundering Policy

Regulatory Framework

United States

United Kingdom

Canada