AML COMPLIANCE PROGRAM
INTRODUCTION
The United States government has made the prevention of money laundering a regulatory and legal priority of the highest order. The events of September 11, 2001 brought to the forefront the importance of preventing money laundering at financial institutions, including money services businesses. Those terrorist acts highlighted the critical role laundered money plays in terrorism – in this case to finance illegal activities and terrorist acts.
Kaah Express is a money services business (MSB). It is required to comply with the laws and regulations that have been designed to stop money laundering. Everyone who is part of Kaah – employees and agents – must help ensure that our company complies with these laws and regulations.
Kaah has developed this Program to state its policies and procedures that, if followed, are designed to ensure that the transactions processed by its agents and employees comply with all applicable antimoney laundering (“AML”) laws and regulations. Under Federal law, all MSBs must develop, administer, and maintain a compliance program that involves monitoring their operations for compliance.
To underscore the Company’s commitment to the goals and objectives addressed in this Program, Kaah’s board of directors conducts an annual review of this manual and the effectiveness of its Program. Whenever the Board approves changes to its Program, as a result of changes in the laws or regulations or business procedures, it will ensure that all employees and agents promptly receive all necessary information on and assistance in implementing those changes.
Kaah’s Compliance Program has four components:
- Internal Controls, which include this manual, the policies and procedures, key features of its database for recording transaction information, and other rules and requirements;
- A Compliance Officer, whose primary responsibility is to ensure compliance at Kaah with AML laws and regulations;
- Training of employees and agents on an ongoing basis to ensure they have adequate knowledge of AML requirements, as well as keeping them abreast of current forms of and trends in money laundering; and
- Independent Testing, which is a careful review of the compliance program, and specifically its internal controls, by a third party who is not involved in managing that program.
