Anti-Money Laundering (AML) Policy

1. Policy Statement

Relier Group, LLC ("Relier") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy establishes our framework for compliance with all applicable laws and regulations, including:

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• Financial Action Task Force (FATF) recommendations

2. AML Compliance Officer

Relier has designated an AML Compliance Officer responsible for:

• Overseeing the AML compliance program
• Ensuring staff training and awareness
• Monitoring transactions for suspicious activity
• Filing Suspicious Activity Reports (SARs) with FinCEN
• Maintaining records and documentation
• Coordinating with law enforcement and regulatory agencies

3. Customer Due Diligence (CDD)

3.1 Standard Due Diligence

For all customers, we perform standard due diligence including:

• Identity verification (see KYC Policy)
• Address verification
• Purpose and nature of business relationship
• Source of funds verification
• Expected transaction patterns and volumes

3.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required for high-risk customers, including:

• Politically Exposed Persons (PEPs) and their close associates
• Customers from high-risk or sanctioned jurisdictions
• Businesses with complex ownership structures
• Cash-intensive businesses
• Non-profit organizations and charities
• Money service businesses (MSBs)
• Customers with unusual transaction patterns

3.3 Ongoing Monitoring

All customer relationships are subject to ongoing monitoring, including:

• Regular review of account activity
• Screening against updated sanctions lists
• Periodic refresh of customer information
• Investigation of unusual or suspicious transactions

4. Transaction Monitoring

4.1 Automated Systems

Relier employs automated transaction monitoring systems that flag:

• Transactions exceeding defined thresholds
• Rapid movement of funds
• Structured transactions (potential structuring/smurfing)
• Transactions involving high-risk jurisdictions
• Unusual patterns inconsistent with customer profile
• Multiple transactions just below reporting thresholds

4.2 Manual Review

Flagged transactions undergo manual review by our compliance team to determine if:

• The activity is consistent with the customer's profile
• There is a legitimate business purpose
• Additional information or documentation is needed
• The activity should be reported as suspicious

5. Suspicious Activity Reporting

5.1 Red Flags

Indicators of potentially suspicious activity include:

• Customer reluctance to provide identification or information
• Provision of false, incomplete, or suspicious documentation
• Unusual concern about reporting or record-keeping requirements
• Transactions with no apparent business or lawful purpose
• Frequent large cash transactions
• Transactions structured to avoid reporting requirements
• Use of multiple accounts or locations without logical reason
• Rapid movement of funds, especially internationally
• Transactions involving known high-risk countries
• Customer behavior that is secretive, evasive, or unusual

5.2 Reporting Requirements

When suspicious activity is identified, Relier will:

• Document all relevant facts and circumstances
• Conduct an internal investigation
• File a Suspicious Activity Report (SAR) with FinCEN within 30 days
• Maintain confidentiality of the SAR filing
• Not disclose to the customer that a SAR has been filed
• Retain all supporting documentation for at least 5 years

6. OFAC Sanctions Screening

6.1 Screening Requirements

All customers, transactions, and business partners are screened against:

• OFAC Specially Designated Nationals (SDN) List
• OFAC Consolidated Sanctions List
• Foreign Sanctions Evaders List
• Sectoral Sanctions Identifications List
• UN Sanctions Lists
• EU Sanctions Lists

6.2 Screening Frequency

• Pre-onboarding: Before establishing any business relationship
• Real-time: At the point of each transaction
• Batch screening: Daily screening of existing customer base
• Event-driven: When sanctions lists are updated

6.3 Match Procedures

When a potential match is identified:

• Transaction is immediately blocked pending investigation
• Compliance officer conducts detailed review
• If confirmed match: transaction is rejected, assets frozen, and OFAC notified within 10 days
• If false positive: transaction may proceed after documentation

7. Geographic Risk Assessment

7.1 High-Risk Jurisdictions

Relier exercises heightened scrutiny for transactions involving jurisdictions identified as high-risk by:

• FATF (countries with strategic AML/CFT deficiencies)
• OFAC (sanctioned or embargoed countries)
• U.S. State Department (countries of concern)

7.2 Prohibited Jurisdictions

Relier does not conduct business with individuals or entities in comprehensively sanctioned jurisdictions, including (but not limited to):

• Cuba
• Iran
• North Korea
• Syria
• Crimea region of Ukraine
• Donetsk and Luhansk regions of Ukraine

8. Record Keeping

Relier maintains comprehensive records including:

• Customer records: 5 years after account closure
• Transaction records: 5 years from transaction date
• SARs and supporting documentation: 5 years from filing date
• Currency Transaction Reports (CTRs): 5 years from filing date
• Internal investigation reports: 5 years minimum
• Training records: 5 years

9. Employee Training

All employees receive AML training:

• New hires: Initial AML training within 30 days
• Annual training: Refresher training for all staff
• Role-specific training: Enhanced training for high-risk positions
• Training topics:
  • AML laws and regulations
  • Red flag indicators
  • Reporting procedures
  • Confidentiality requirements
  • Consequences of non-compliance

10. Independent Testing and Audit

Relier's AML program is subject to:

• Annual independent audit by qualified third party
• Quarterly internal compliance reviews
• Testing of transaction monitoring systems
• Review of SAR filings and investigations
• Assessment of training effectiveness

11. Third-Party Risk Management

All business partners, vendors, and agents are subject to due diligence including:

• AML/KYC policy review
• Sanctions screening
• Reputation checks
• Ongoing monitoring
• Contractual AML compliance obligations

12. Whistleblower Protection

Relier encourages employees to report suspected violations without fear of retaliation. Reports can be made:

13. Consequences of Non-Compliance

Violations of this AML Policy may result in:

• Disciplinary action up to and including termination
• Civil and criminal penalties under federal law
• Regulatory sanctions against Relier
• Reputational damage
• Loss of licenses and operating authority

14. Policy Review and Updates

This AML Policy is reviewed and updated:

• Annually as part of independent audit
• When regulations or laws change
• Following significant compliance incidents
• When business operations materially change

15. Contact Information