Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Purpose & Scope

This policy ensures full compliance with the U.S. Bank Secrecy Act (BSA), USA PATRIOT Act, Office of Foreign Assets Control (OFAC) sanctions, and applicable international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations. It reinforces our zero-tolerance stance toward illicit financial flows.

2. Customer Due Diligence (CDD) & Identity Verification

Prior to executing service agreements or onboarding enterprise clients, we enforce:

• Identity Verification: Collection and verification of official government-issued photo IDs (passports, driver's licenses) for beneficial owners and corporate signatories.
• Entity Verification: Validation of Certificates of Incorporation, Articles of Organization, Tax Identification Numbers (EIN), and Ultimate Beneficial Ownership (UBO) structures.
• Enhanced Due Diligence (EDD): Additional background screening and source-of-wealth scrutiny for higher-value contracts, complex corporate structures, or high-risk jurisdictions.

3. Transaction Monitoring & Payment Controls

We systematically monitor financial transactions and payment flows:

• All client retainers, milestones, and software development payments must originate from registered corporate accounts or verified payment cards under the client's legal name.
• Third-party payments from unrelated individuals or entities are strictly rejected.
• Unusual payment velocity, unexpected high-volume splits, or mismatched billing origins trigger automated compliance review and escalation.

4. Statutory Record Keeping

All verification dossiers, identification documents, client contracts, and audit trails of incoming/outgoing funds are maintained securely for a minimum of five (5) years following the completion of the project or termination of the business relationship.

5. Risk-Based Approach (RBA)

We implement a dynamic Risk-Based Approach, assessing risk based on geographic location, client business sector, transaction size, and product delivery model to allocate appropriate compliance resources.

6. Suspicious Activity Reporting (SAR)

If any transaction or engagement exhibits indicators of fraudulent intent, sanctions evasion, or money laundering, Plus Flow Digital reserves the right to file Suspicious Activity Reports (SAR) with relevant Financial Intelligence Units (FIU) or law enforcement authorities without prior client notice.

7. Staff Training & Compliance Culture

All account directors, project managers, and finance personnel receive regular training on AML red flags, KYC documentation verification standards, and escalation procedures.

8. Client Cooperation & Consent

By utilizing our services, clients consent to provide complete, truthful information and agree to cooperate with all standard and enhanced KYC/AML requests. Refusal to supply necessary verification materials will result in immediate suspension or termination of services.