Peter Deng Express, Ltd (“AG”) is a Ugandan private company formed under the Companies Act of Uganda. AG’s business includes operating a money wire transfer business. Such business started solely in Africa but is expanding to include money wire transfers made from the United State to African countries, and may come to include some transfers from African countries to the United States.
AG is a small company but is committed to combating money laundering. AG management will actively search for suspicious activity. AG is committed to complying with the Banking Secrecy Act (“BSA”) and other applicable regulations or laws.
Money Laundering involves the introduction of illegally obtained currency into the banking system OR using the banking system to illegally hide currency that was lawfully obtained. Criminals obtain currency and often seek to deposit currency into banks or other companies dealing with currency. Such deposits or transfers of currency can include wire money transfer services such as AG provides. Thus companies providing wire money transfer services, such as AG, must be diligent in detecting and reporting suspicious activity.
If this Anti-Money Laundering Policy is found to conflict with any applicable law or regulation, that imposes different or additional requirements, such other law or regulation will control and be deemed to supplement this policy.
To help ensure compliance with the BSA, AG will appoint and maintain an Anti-Money Laundering Policy Compliance Officer (“AMLP Compliance Officer”).
The initial AMLP shall be Peter Deng, who is the managing member, and director and majority shareholder of the Company. Any subsequent AMLP Compliance Officer shall report to the Managing Director of AG.
For persons wishing to transfer funds using AG’s services, the customer identification information (name and address) shall be collected and recorded. Customer’s identities shall be confirmed using the following identification means:
A. For U.S. Customer - One of the following forms of identification with a picture:
1) U. S. drivers license issued by a state department of motor vehicles
2) U.S. Passport
3) Alien registration card
If none of these forms of identification is available, the transaction can still be completed if the customer can supply two (2) of the following forms of ID.
1) Employer identification card
2) Major credit card
3) Two (2) current utility bills, showing the customer’s current address
B. For Customers outside the United States:
One of the following forms of identification with a picture:
1) A drivers license issued by the appropriate authority in the country or province where the transaction is made
2) Passport
3) A refugee identification card issued by the United Nations High Commissioner for Refugees
If none of these forms of identification is available, the transaction can still be completed if the customer can supply proof of a cell phone account and if he or she can also supply proof of the clan where he or she come from.
Any money transfer involving the transfer of over $10,000.00 in a single day by a customer shall require the completion of a Currency Transaction Report (CTR). AG employees are required to report any such transactions to the AMLP Compliance Officer, and provide such Officer with the information needed to complete and file a CTR report with FinCEN. The AMLP Compliance Officer will promptly file such CTR report. The $10,000 per day transaction trigger to file a CTR will be modified if and as necessary to comply with any CTR reporting requirements.
AG employees are prohibited from re-structuring any requested customer money transfer requests, involving the transfer of more than $10,000 in one day by a customer, to evade, prevent or avoid the need to file a CTR.
The AMLP Compliance Officer will review records of money transfer transactions conducted by AG on a weekly basis, to look for and identify any AG customers who have transferred over $10,000 in one day by using multiple AG locations or agents. If daily aggregated transactions exceeding $10,000 for a single customer are detected, the AMLP Compliance Officer will file a CTR with respect to such aggregated activity.
If a CTR is filed, AMLP Compliance Officer will file the CTR with the appropriate legal and regulatory authorities. All supporting evidence for the CTR will be maintained for a minimum of five (5) years, and will be securely stored. The AMLP Compliance Officer will create quarterly reports, to summarize filed CTR’s, along with brief a summary as to dollar amount of the suspicious activities and why they were deemed that way.
It is impossible to define all activity that would qualify as suspicious. However, the following guidelines quantify the types of suspicious activities that AG will monitor for.
Red Flags that may indicate suspicious activity include:
1. The customer appears to intentionally avoid reporting requirements by splitting transactions.
2. The customer makes large and frequent transfers to or from unrelated third persons with no reasonably appearing legitimate purpose.
3. The customer makes a large deposit followed in short
time by numerous smaller transactions.
4. The customer uses unusual or suspicious identification documents that cannot be readily verified.
5. The customer shows unusual concern for secrecy, particularly with respect to his or her identity, the reason for the transaction, or any transaction reporting requirements.
6. The customer provides forms of identification with conflicting information, or which appear expired or false.
7. The customer seeks to transfer funds without normal identifying information or in as manner to attempt to hide the identity of the sender or recipient.
8. The customer provides inconsistent information when questioned.
9. The AG agent has reason to know or reasonably believe that the money being transferred was from illegal activities, or is being transferred to hide or disguise funds from illegal activities.ss
1. Transactions totaling or aggregating at least $2,000 in AG money transfers where the AG agent knows, reasonably suspects, or has reasonable grounds to suspect that the transaction(s) involved illegal activities, or is being transferred to hide or disguise funds from illegal activities as part of a plan to violate or evade transaction reporting law requirements.
2. Transactions where AG detects that the transaction was designed to evade currency-reporting requirements, by structuring or other means.
3. AG reasonably concludes that the transfer conducted using its services was conducted to facilitate criminal activity.
4. The transfer involves actions of AG agents or employees that provide reasonable grounds to conclude that such agent or employee is facilitating illegal activity or avoidance of money transfer reporting requirements.
When it suspicious activity is discovered, the suspicious activity will be reported to the Anti-Money Laundering Policy Compliance Officer (“AMLP Compliance Officer”). The initial AMLP Compliance Officer shall be Peter Deng, who is the managing director, and director and majority shareholder of the Company.
The AMLP Compliance Officer will have ten (10) business days to conduct the review and make his determination if an SAR should be filed.
If an SAR is filed, AMLP Compliance Officer will file the SAR with the appropriate legal and regulatory authorities. All supporting evidence for the SAR will be maintained for a minimum of five (5) years, and will be securely stored. The AMLP Compliance Officer will create quarterly reports, to summarize filed SAR’s, along with brief a summary as to dollar amount of the suspicious activities and why they were deemed that way.
All AG employees and agents will receive training once a year on how to identify money-laundering operations. (New employees that have direct contact with customers will receive initial training within the first four weeks of employment.) AG employees and agents shall be provided a copy of this Policy and instructed and trained to fully and promptly report any transactions requiring a CTR, or which involve suspicious activity, to the AMLP Compliance Officer.
The AMLP Compliance Officer will review AG transaction records at least once a week to look for possible BSA violations, prepare and file the reports described above. And once a year will review compliance with this Policy with the Managing Director and the Board of Directors of the Company.
At a minimum of once a year, the AMLP Compliance Officer will review compliance with this Policy with the Managing Director and the Board of Directors of the Company, and provide copies of the monthly reports generated under this policy. Revisions to this policy will be made and distributed to all AG agents and employees if the BSA or currency reporting transaction laws or regulations change to require new or different requirements on AG. If such changes are adopted, the AG employees and agents shall be trained as to such changes.ss