ANTI-MONEY LAUNDERING POLICY STATEMENT
It is Kaah’s policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. At the same time, it is Kaah’s policy to comply with all applicable Federal and state laws in the discharge of its functions as a licensed money transmitter.
Kaah Express F.S. Inc. has created this handbook to assist its directors, officers, employees, and agents to comply with the anti-money laundering laws and regulations, including the Currency and Foreign Transactions Reporting Act, also known as the Bank Secrecy Act (“BSA”). 31 USC §§ 5311-5330 and 12 USC §§ 1818(s), 1829(b), and 1951-1959; the BSA’s implementing regulations, 31 CFR Chapter 10, the Money Laundering Suppression Act; the “Drug Kingpin Law” under the Foreign Narcotics Kingpin Designation Act of 1999; Public Law 106-120, and the Money Laundering and Financial Crimes Strategy Act of 1998, Tile 31 U.S.C. Sec. 5340-5355.
Kaah is also required to comply with state-specific laws, such as the Colorado Banking Board Rule MO7, Employee Money Laundering Affirmation (MO8), as well as the Colorado Revised Statutes (C.R.S) Additionally, the Company and its staff understand that they must comply with the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001 title III of the U.S.A Patriot Act of 2001, Public Law 107-56 as enacted October 26, 2001, and with the Office of Foreign Assets Control (“OFAC”) Rules and the Executive Orders Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten To Commit, or Support Terrorism, issued under the International Emergency Economic Powers Act.
Because the anti-money laundering regulatory landscape changes, Kaah will amend this manual from time to time, as compliance requirements demand. The Compliance Officer is responsible for identifying needed changes and ensuring that those changes are made in a timely way. However, all directors, officers, employees, and agents are encouraged to propose changes intended to better achieve the Company’s stated goal of “full compliance with all applicable laws in each endeavor of the Company