Greelance Inc., a Domestic Profit Corporation, has been duly incorporated under the laws of the State of Georgia on March 8, 2022. Greelance Inc. and its team uphold their reputation of delivering services with the highest standards of business ethics and integrity. Greelance Inc. has its plan to extend its operation worldwide and to achieve its objective, Greelance Inc. has started its operation from its Head Office in Georgia and Branch Office in Texas.
Greelance Inc. is headed by Jimmy Idemudia, who is a US Army veteran and a former Google Cloud Architect. Jimmy has over 20 years of experience in technology architecture and management. Jimmy has extensive expertise in the implementation of Cloud, Blockchain, Artificial Intelligence, Robotics, and IoT technologies.
Greelance Inc. has a team of experts, who have excelled in their respective fields.
We, as a team, recognize the utmost importance of ensuring that our business activities are managed to the highest standards and that all the activities shall be legal and in compliance with the respective laws. That includes making sure that when we onboard new customers, or recertify existing relationships, we have a full understanding of their identity and aspirations. By doing so, we aim to ensure that our procedures are thorough and transparent and that it enables our business to sustain long-lasting and valuable customer relationships.
When it comes to Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, we have implemented scrutinizing processes, systems, and controls to comply strictly with AML/ CFT Laws.
The Corporation is regulated by various U.S. Federal & State Laws, as well as other U.S. and Non-U.S. governmental agencies that have administrative and supervisory authority over certain legal entities in those jurisdictions where the Corporation operates. Regulatory authorities will focus on Customer background and work to curb the menace of identity theft, money laundering, terrorist financing, etc. As a result, Greelance Inc. has to follow stringent KYC norms, and restrictions on cash transactions, and ensure strict AML/ CFT compliance.
The Corporation has implemented a risk-based global Anti-Money Laundering and CFT Compliance Program (“AML/ CFT Program”) designed to comply with AML laws and regulations in the U.S., including the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable laws and regulations relating to the prevention of money laundering and terrorist financing in the jurisdiction, where the Corporation operates.
Our Corporate KYC Policy creates the framework for customer identity verification and document validation processes to ensure quick and efficient processing of KYC and AML requirements at our head office and branch office to comply with all laws and also not to lose potential customers. Besides electronic surveillance, our AML Compliance Officer will be duty-bound to train each staff about customer due diligence (CDD) and enhanced due diligence (EDD), resulting in quick efficient identification and constant monitoring/tracking of high-risk customers; Corporationwide risk assessments; and adequate screening of employees via record retention and electronic checks.
The KYC practices permit us to vigilantly address customer legitimacy concerns. The identity verification process/program helps us ensure that customers are, who they claim to be, business entities are legitimate, all data provided by them is complete and accurate, and the customer is not a part of any sanctions list or a member of a banned or suspected organization.
Greelance Inc. shall remain duty-bound with the Application of FinCEN’s Regulations to Certain Business Models Involving Virtual Currencies/Tokens/NFTs, about Anti-Money Laundering and Countering the Financing of Terrorism. We shall also comply with the regulations specifying how financial institutions should incorporate “cybercrime, including relevant cybersecurity and virtual currency considerations,” among other priorities, into their AML/CFT Policy & Procedure Manual.
As one customer or document verification lapse can hurt our good reputation and seriously affect our business, I am asking each employee of Greelance Inc. to personally commit themselves to understanding and rigorously following our Corporate KYC/AML/CFT Policy.
Thank you for your kind cooperation in continuing to conduct our business according to the highest legal and ethical standards.
(Jimmy Idemudia )
Incorporator, President & CEO
It is the policy of Greelance Inc. to prohibit and actively prevent money laundering or any other such suspicious activity that facilitates money laundering or the funding of terrorists or criminal activities by adhering to all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.
The Members/Owners of Greelance Inc. establish integrity as a key commitment to upholding strict standards of ethical conduct and hence preservation of stable value for society’s confidence. Keeping in view, the national and international regulations made for the prevention of criminal activities, such as money laundering and terrorism financing, etc., Greelance Inc. strictly implements Know Your Customer (KYC), Anti-Money Laundering (AML), and Counters the Financing of Terrorism (CFT) regulatory guidelines and procedures.
Greelance Inc.’s priorities are to take necessary steps to restrict (1) corruption; (2) cybercrime, including relevant cyber security and virtual currency considerations; (3) foreign and domestic terrorist financing; (4) fraud; (5) transnational criminal organization activity; (6) drug trafficking organization activity; (7) human trafficking and human smuggling; (8) restriction on cash and suspicious transactions; and (9) proliferation financing and reporting incidents to FinCEN and other appropriate AML/ CFT Federal and State Regulators.
Money Laundering is generally referred to as engaging in acts to conceal or disguise the true origins of criminally derived proceeds. The aim of AML/CFT Policies, Procedure & Control is such that the proceeds that appear to have derived from illegitimate origins shall be detected at an initial stage and reported to the Federal and State controlling authorities.
Generally, money laundering occurs in three stages –
Although the cash is rarely deposited into the securities accounts, however, the securities industry can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Some prominent methods/examples of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cybercrimes, and other investment-related fraudulent activities.
Terrorist funding may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the illegitimate funds or their intended use, which could be used for other criminal purposes. In addition to funding through charitable donations, legitimate sources also include foreign government sponsors, business ownership, and personal employment.
Terrorism financing is defined as:
the provision or collection of funds by any means, direct or indirect, with the goal or knowledge that they will be used, in whole or in part, to carry out any terrorist act.
Greelance Inc.’s AML/CFT policies are designed to ensure compliance with all applicable BSA Policy, Regulations and FINRA rules and shall be reviewed and updated regularly to ensure that appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business. We shall comply with all the Anti-Money Laundering Act and Regulations. We will design an Internal Audit and Internal Control System in such a way that the work of one employee would be checked by another and no employee would have independent control of the operation.
Greelance Inc. is committed to the highest standards of KYC and AML compliance and also ensures that our management and employees would adhere to these standards in preventing the use of Greelance Inc. services from being used for money laundering or terrorism financing. All the members/employees of Greelance Inc. would actively participate in preventing the services provided by us from being exploited by criminals and terrorists for money laundering purposes. They would be required to protect, detect and report to AML Compliance Officer all the potential instances of money laundering, terrorist financing, or other illegal activity.
Central banks and regulators around the world have intensified their focus on ensuring that strong due diligence, screening, and anti-money laundering (AML) protocols are in place to identify the true source of funds and overall risk exposure. Regulations such as the Financial Action Task Force (FATF), Financial Crimes Enforcement Network Customer Due Diligence (FinCEN CDD), and the AML Directive have been introduced to ensure companies and organizations follow stringent due diligence processes. Thus, the global regulatory landscape of KYC and AML programs has compelled companies and financial organizations to strengthen their customer due diligence processes.
Know Your Customer (KYC), as a business function, has become increasingly important worldwide to prevent money laundering activities, terrorism financing, identity theft, and other financial frauds. KYC and AML regulatory compliance are emerging as one of the most important priorities for companies and other financial institutions globally. Greelance Inc. shall follow all procedures and policies to comply with it strictly.
It is the Corporation’s policy to select an AML/CFT Compliance Officer, who must be a person in a senior managerial position with suitable professional experience and competence. He must have ample professional knowledge and experience in working with the Bank Secrecy Act (BSA) and its implementing regulations.
AML/CFT Compliance Officer shall perform the following duties:
The AML Compliance Officer is vested with full responsibility and authority to enforce the Corporation’s AML/CFT program. Greelance Inc. will provide FINRA with contact information for the AML/CFT Compliance Officer through the FINRA Contact System (FCS), including: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile (if any).
Greelance Inc. will promptly notify FINRA of any of the changes in this information through FCS and will further review, and if necessary, update this information within 17 business days after the end of each calendar year.
The annual review of FCS information will be conducted by [Name] who will further complete all the necessary updates being provided no later than 17 business days following the end of each calendar year. In addition to this, if there is any amendment in the information, [Name] will update such information promptly, but in any event not later than 30 days following the change. Our AML/CFT policy obligates the AML Compliance Officer to ensure that proper AML records are kept and maintained. When warranted, the AML Compliance Officer will ensure that the Suspicious Activity Reports are filed with the Financial Crimes Enforcement Network (FinCEN).
Keeping in view, the U.S. Treasury’s final regulations, it is the policy of the Greelance Inc. that it will respond to any FinCEN request received regarding the accounts or transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction/s with, each individual, entity, or organization named in FinCEN’s request. When an information request is received, the AML Compliance Officer (AMLCO) is In-charge of dealing with it and similar requests in the future.
5.1 SHARING INFORMATION WITH FEDERAL LAW ENFORCEMENT AGENCY:
If FinCEN requests, we are required to search the current accounts and transactions, accounts maintained by a named suspect during the preceding 12 months, and transactions conducted by or on behalf of or with a named subject during the preceding six months. If we find a match, we ensure to report it to FinCEN by completing FinCEN’s subject information form on time. If we search our records and do not find a matching account or transaction, then we will not reply as allowed under Section 314(a) of the PATRIOT Act. Still, Greelance Inc. shall take all reasonable care to respond to Federal and State Authorities.
It is the policy of Greelance Inc. to not disclose the fact that FinCEN has requested or obtained any/certain information from us, except to the extent necessary to comply with the information request. We will maintain mandatory/required procedures necessary to protect the security and confidentiality of the requests received from FinCEN, as required by Section 501 of the Gramm-Leach-Bliley Act. We will direct any questions, if we have, regarding the request to the requesting Federal law enforcement agency as designated in the 314(a) request.
We will not use the information provided to FinCEN for any purpose other than (1) to report to FinCEN as required under Section 314 of the PATRIOT Act; (2) to determine whether to establish or maintain an account, or to engage in a transaction; or (3) to assist in complying with any requirement of Section 314 of the PATRIOT Act.
5.2 SHARING INFORMATION WITH OTHER FINANCIAL INSTITUTIONS:
It is the policy of Greelance Inc. that it will share the necessary information about those suspected of being involved in terrorist financing and money laundering activities with other financial institutions to identify and report activities that may involve terrorist acts or money laundering activities and to determine whether to establish or maintain an account or engage in a transaction with them.
We ensure to file an initial notice with FinCEN before any sharing occurs and annual notices afterward. We will use the notice form found at https://bsaefiling.fincen.treas.gov/main.html Before we share information with another financial institution/s, we will take reasonable steps to verify that the other financial institution has submitted the requisite notice to FinCEN, either by obtaining guidance from the financial institution or by consulting a list of such financial institutions that FinCEN will make available. We understand/acknowledge that this requirement applies even to the financial institutions with whom we are affiliated, and hence we will obtain the requisite notices from affiliates and would follow all required procedures.
We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, including segregating it from the Corporation’s other books and records.
POLICY AND PROCEDURE:
Greelance Inc.’s AML/CFT policies, procedures, and internal controls ensure that before engaging in any kind of money service activity (including but not limited to check cash, money orders or wire transfers, etc.) which potentially may involve money laundering, and on an ongoing basis, we will properly investigate to ensure that a customer does not appear on the Treasury’s OFAC “Specifically Designated Nationals and Blocked Persons” list, SDN list, and is not from, or engaged in any transactions with the people or entities from embargoed countries and regions listed on the OFAC website.
Because the OFAC Website is updated frequently, we ensure to consult the list regularly and subscribe to receive the updates when they occur. We may, if necessary, access/inspect these lists through various software programs to ensure speed and accuracy. We will also review the existing accounts against these lists when they are updated and we will document our review.
The policies and procedural norms of Greelance Inc. also ensure that if we suspect a customer, or someone with or for whom the customer is transacting, is on the SDN List or is from or engaging in transactions with a person or entity located in an embargoed country or region, we will reject the transaction and/or block the customer’s assets and file blocked assets and/or rejected transaction form with OFAC.
We may also call the OFAC Hotline at 1-800-540- 6322/ 1-202-622-249.
Greelance Inc. AML policies and procedures are intended to ensure that, before establishing any relationship with the Client/Freelancer/Agency/Platform User, all reasonable and practical measures are taken to verify the Client/Freelancer/Agency/Platform Users’ identity. Further, Greelance Inc. shall verify that any third party upon whom Greelance Inc. is relying for Client/Freelancer/Agency/Platform User identification, adheres to the same standards.
The AML Compliance Officer of Greelance Inc. may determine to apply enhanced measures for reasons other than those discussed below. Employees are encouraged to provide the Compliance Officer with any revisions in the KYC they consider appropriate.
Copies of all documents reviewed or checklists completed in connection with the Client/Freelancer/Agency/Platform User Identification Procedures shall be kept in accordance with Greelance Inc. Client/Freelancer/Agency/Platform User Records Retention policies.
7.1.1. Client/Freelancer/Agency/Platform User Identification Procedures for Natural Persons;
Greelance Inc. shall take reasonable steps to obtain adequate documentation of an individual Client/Freelancer/Agency/Platform User’s name, residential address, telephone contact information, mobile phone number, email address, date of birth and office address.
The following is a list of additional information that may be requested:
7.1.2. Client/Freelancer/Agency/Platform User Identification Procedures for Corporations, Trusts, and other Legal Entities;
Greelance Inc. shall take reasonable steps to verify the entity’s name, including its registered name and registration number, address, email address, phone number and authority of the person opening an account at Greelance Inc.
The following is a list of additional information that may be requested:
7.1.3. High-Risk Client/Freelancer/Agency/Platform Users;
Greelance Inc.’s AML/CFT policies, procedures, and internal controls bound the Compliance Officer to adopt enhanced due diligence procedures compared to the routine Client/Freelancer/Agency/Platform User Identification Procedures.
Following are the illustrations of Client/Freelancer/Agency/Platform Users who pose a high money laundering risk:
Note: Non-Cooperative Jurisdiction means any foreign country that has been designated as non-cooperative with international AML principles or procedures by an intergovernmental group or organization, such as the Financial Action Task Force on Money Laundering (“FATF”).
7.1.4. Enhanced User Identification Procedural norms for ‘High-Risk’ Natural Persons;
Greelance Inc.’s AML/CFT policies, procedures, and internal controls are designed in a manner to ensure Enhanced Client/Freelancer/Agency/Platform User Identification Procedures for ‘high-risk’ natural persons as Client/Freelancer/Agency/Platform Users include, but are not limited to, the following:
7.1.5. Enhanced User Identification Procedures for ‘High-Risk’ Corporations, Trusts and Other Legal Entities;
Enhanced User Identification Procedures for ‘high risk’ corporations, partnerships and other legal entities include, but are not limited to, the following :
OTHER IDENTIFICATION/VERIFICATION STEPS:
7.2 Customers Who Refuse to Provide Information:
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Greelance Inc. will not open any new account and, after considering the risks involved, consider closing of any existing account. In either case, our AML Compliance Officer shall be notified so that we could determine whether we should report the situation to FinCEN on a SAR or not.
7.3 Verifying Information:
Based on the risk involved, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify the document and the accuracy of the information we get about our customers. In verifying customer identity, we will analyze any logical inconsistencies in the information we obtain.
We ensure to verify the customer’s identity through documentary evidence, non-documentary evidence, or both. We will use the documents to verify customer identity when appropriate documents are available
In the light of the increased instances of identity fraud, we have designed our procedure in a manner such that we will supplement the use of documentary evidence by using the non-documentary means, as described below, whenever possible. If we are still unsure if we know the genuine identity of the consumer after employing documentary proof, we may use such non-documentary methods. We will analyze whether there is logical consistency among the identifying information provided, such as the customer’s name, street address, zip code, telephone number (if provided), date of/ birth, and social security number, while analyzing/assessing the verification information.
Appropriate documents for verification of the identity of customers include, but are not limited to, the following:
We know that we are not required to take steps to determine whether the document provided to us by the customer for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. However, if we observe that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity.
Our corporation may use any or all of the following non-documentary methods for verification of identity:
non-documentary methods would be used for verification in the following situations: (1) when the customer fails/is not able to present an unexpired government-issued identification document with his photograph or other similar safeguards; (2) when the Company is not familiar with the documents, that the customer presents for identification verification; (3) when there are other circumstances that increase the risk that the Company will not be able to verify the true identity of the customer through documentary means.
We ensure to verify the information within a reasonable time before a transaction is completed. Depending upon the nature of the requested transaction, we have the authority to refuse to complete a transaction before we completely verify the information, or in some other instances when we need more time, we may, pending the verification, restrict the types of transactions or dollar amount of transactions.
If we find suspicious information that indicates possible money laundering or terrorist financing activity, we will, after internal consultation with the Corporation’s AML compliance officer, file a SAR in accordance with applicable law and regulation.—
7.4 Lack of Verification:
When the true identity of a customer cannot be obtained, we will do the following:
(1) not open an account;
(2) impose certain terms under which a customer may conduct restricted/only specific transactions while we attempt to verify the customer’s identity;
(3) If attempts to authenticate a customer’s identity fail, close the account; and
(4) determine whether SAR is required to be filed in accordance with applicable laws and regulations.
We will prepare a document for our verification, including all identifying information provided by a customer, the methods used, and the results of verification, and will also mention the resolution of any discrepancy in the identifying information.
We will also keep records containing a description of any document that we relied upon to verify a customer’s identity, noting the type of document, the document’s identifying number, the place of issuance, and, if applicable, the date of issuance and expiration date.
In the context of/in relation to non-documentary verification, we ensure to retain the documents that describe the methods and the results of any measures we took in order to verify the identity of a customer.
We ensure to maintain records of all identification information for five years after the account has been closed and is readily accessible for the first two years. We will retain the records prepared for/at the time of verification of the customer’s identity for five years after the record is made.
7.6 Comparison with Government-Provided Lists of Terrorists:
Our Corporation, on receiving the notice that the Federal government agency has issued a list of known or suspected terrorists, within a reasonable period of time, after an account is opened or transaction is completed (or earlier, if required by another Federal law or regulation or Federal directive duly issued in connection with/ in relation to an applicable list), we will check to see if a customer is listed on any list of known or suspected terrorists or terrorist groups issued by any Federal government agency and identified as such by Treasury in collaboration with the Federal functional regulators.
We will follow all the Federal directives issued in connection with such lists. We will continue to comply with the Treasury’s OFAC rules prohibiting the transactions with certain foreign countries or their nationals as mentioned above.
7.7 Notice to Customers:
We will provide notice to customers that the Corporation is requesting information from them to verify their identities, as required by Federal law. We will notify/ give notice to the customers regarding the policy either verbally or as a plainly posted notice such as:
To help the government in fighting against the funding of terrorism and money laundering activities, Federal law requires us to obtain, verify, and record sufficient information that identifies each person who cashes checks, wire funds or engages in other financial services with this establishment. We will ask the customer for his name, address and other information that will allow us to identify them. We may also ask to see the customer’s driver’s license or other identifying documents.
7.8 Reliance on Other Financial Institutions for Identity Verification:
Under the following circumstances, we may rely upon the performance of other financial institutions for some or all of the elements of our customer identification program with respect to any customer that is engaged or is engaging in a money service transaction with the other financial institution to provide or engage in services, dealings, or other financial transactions:
Greelance Inc.’s policy is to gather information that allows us to analyze the purpose and nature of each Client/Freelancer/Agency/Platform User’s engagement with the Corporation.
The Corporation’s policy is to keep any information received during a CDD for a minimum of five years after the relevant business or transaction with the customer is completed.
If a sufficient understanding of the nature and purpose of the Client/Freelancer/Agency/Platform User’s business with us cannot be obtained and it/he/she fails to clarify the same within a reasonable time, our Corporation shall immediately withdraw its services and the said account shall be suspended or terminated as per the instructions of the AML/CFT Compliance Officer.
Customer Identification Program;
Greelance Inc. has implemented the Customer Identification Program for the Platform Users:
If a potential or existing customer either refuses to provide the requested customer information when requested, or appears to have intentionally provided misleading information, Greelance Inc. will not open any new account of that customer and, after considering the risks involved, consider closing any existing account for the customer. In either case, our AML Compliance officer will be notified so that a determination can be made as to whether the situation should be reported to FinCEN (i.e., file a SAR).
If an advisor is unable to verify the customer’s identification, Greelance Inc. will use non-documentary means to verify that customer’s identity.
The primary non-documentary process shall be to run the customer’s number from their identification document through an independent verification database. If no match is found or other ‘red flags’ that signal possible money laundering or terrorist financing exist, additional non-documentary methods may be used to verify a customer’s identity such as:
Identification and Verification of Beneficial Owners:
At the time of opening an account for a legal entity customer, the following information will be collected from each beneficial owner:
(1) the name;
(2) date of birth (for an individual);
(3) an address, which could be a residential or business street address, or residential or business street address of next of kin or another contact individual and
(4) an identification number, which would be a Social Security number (for U.S. persons), or one or more of the following: a passport number and country of issuance, or other similar identification numbers, such as an alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons).
Our corporation will describe any document relied on (noting the type, any identification number, place of issuance and, if any, date of issuance and expiration) for verification.
Understanding the Nature and Purpose of the Customer Relationships:
We will understand the nature and purpose of the customer relationships for the purpose of developing a customer risk profile through the following methods;
Depending upon the facts and circumstances, a customer risk profile may include such information as:
Conducting the Ongoing Monitoring to Identify and Report Suspicious Transactions
It is the policy of our corporation to conduct ongoing monitoring to identify and report the suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers, by using the customer risk profile as a baseline against which the activity of the customer is assessed for suspicious transaction reporting. Point No. 13 describes our techniques for monitoring questionable behavior (Monitoring Accounts for Suspicious Activity).
Greelance Inc. does not establish, maintain, administer, or manage correspondent accounts for foreign banks. A “correspondent account” refers to an account established by a financial institution for a foreign bank in order to receive deposits from; or to handle other financial transactions involving the foreign bank; or to make payments or other disbursements on behalf of the foreign bank.
Greelance Inc. is well aware of the fact that a financial institution is prohibited from establishing, maintaining, administering, or managing a correspondent account for, or on behalf of, a foreign shell bank.
Our corporation ensures that we have duly reviewed our accounts and we do not have, nor do we intend to open or maintain, correspondent accounts for any foreign financial institutions.
Greelance Inc. does not open, maintain, manage, or administer private banking accounts. A “private banking” account refers to an account that requires a minimum aggregate deposit of $1 million, is established for one or more individuals and is assigned to or administered by an officer, employee, or agent of a financial institution acting as a liaison between the financial institution and the direct or beneficial owner of the account.
In addition to this, enhanced due diligence must also be conducted to detect and report transactions that may involve money laundering or the proceeds of foreign corruption.
It is the policy of our Corporation that we will not engage in any kind of money service transactions when we have a reasonable cause to believe that a foreign bank or foreign financial institution is involved in any way and the activity is of suspicious nature.
The policy, procedure and internal controls of Greelance Inc. are designed in such a manner that we would manually monitor a sufficient amount of money service activities in order to permit identification of patterns of unusual size, volume, pattern or type of transactions, geographic factors like whether the jurisdictions designated as “non-cooperative” are involved, or any of the “red flags” has been identified in Section 13. The AML Compliance Officer would be responsible for this monitoring, and will report suspicious activities to the appropriate authorities.
We ensure to create employee guidelines with illustrations/references of suspicious money laundering activity and lists of high-risk Client/Freelancer/Agency/Platform Users whose accounts may warrant further scrutiny. Our AML Compliance Officer would conduct an appropriate investigation before a SAR is filed.
13.1 Emergency Notification to Law Enforcement by Telephone:
It is the policy of Greelance Inc. that while conducting the due diligence we will immediately call the Federal law enforcement when necessary, and especially in these emergencies: a legal or beneficial account holder or a person with whom that account holder is engaged in a transaction is listed on or located in a country or region listed on the OFAC list, an account is held by an entity that is owned or controlled by a person or an entity listed on the OFAC list, a customer tries to use bribery, coercion, or any other similar means to open an account or carry out suspicious activity, such that we have reason to believe that the customer is trying to move illicit cash out of the government’s reach, or we have a reason to believe that the customer is about to use the funds to further an act of terrorism, we ensure to contact the OFAC via its hotline at 1-800-540-6322 or electronically through its website at www.treas.gov/offices/enforcement/ofac.
13.1.1. Detecting Red Flags
Red flags that signal possible money laundering or terrorist financing include, but are not limited to:
13.1.2.Responding to Suspicious Activity and Red Flags:
It is the policy of our corporation that when a member of the staff of Greelance Inc. detects any red flag, he or she will investigate further under the direction of the AML Compliance Officer. This may include gathering/collecting additional information internally or from third-party sources, contacting the government, freezing the account, or filing a Form SAR.
13.1.3.Stopping/continuing of work on suspicion of any such activity:
Greelance Inc. ensures that the moment we receive any report/indication regarding the suspicious activity, we will immediately stop the work in that particular area and try our level best to resolve the issue at its earliest possibility. We will make sure that works of other fields cannot be affected. The AML Compliance Officer will order the authorized officer to inspect the matter.
In our Corporation, AML Compliance Officer shall receive and review internal suspicion reports before deciding whether or not a formal disclosure to the authorities is necessary. If the AML Compliance Officer decides to make a formal disclosure on behalf of the Corporation, he/she would do so by following the proper procedure.
14.1 Filing a Form No. FinCEN 111 about SAR:
It is the policy of Greelance Inc. that we will file Form SAR for any activity (including deposits and transfers) conducted or attempted through our Corporation involving (or in the aggregate) $2,000 or more of funds or assets where we know, suspect, or have reason to suspect:
1) that the transaction involves funds derived from illegal activities or is intended or conducted in order to hide or disguise the funds or assets derived from illegal activity as part of a plan to violate or evade federal laws or regulations or to avoid any kind of transaction reporting requirement under federal law or regulation,
2) that the transaction is designed, whether through structuring or otherwise, to evade the any of the requirements of the BSA regulations,
3) that the transaction does not have any business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and we know, after examining the background, that the possible purpose of the transaction and other facts, is of no reasonable explanation for the transaction, or
4) that the transaction involves the use of Greelance Inc. Platform to facilitate the criminal activitiess.
We ensure not to base our decision on whether to file a SAR solely or whether the transaction falls above a set threshold. We will file a SAR and notify law enforcement regarding all the transactions that raise an identifiable suspicion of criminal, terrorist, or corrupt activities. We shall immediately contact the appropriate federal agency and file a SAR with FinCEN in high-risk instances.
We ensure to report all the suspicious transactions by completing a SAR and we will collect and maintain the supporting documentation as required by the BSA regulations. We ensure to file a SAR no later than 30 calendar days after the date of the initial detection of the facts that constitute a basis for filing a SAR. We may delay submitting the SAR for an additional 30 calendar days if no suspect is identified on the date of initial detection, but in no instance will the reporting be delayed for more than 60 calendar days from the date of initial detection.
We’ll keep copies of any SARs filed, as well as the original or business record equivalent of any supporting documentation, for five years after the SAR is filed. We will identify and maintain the supporting documentation and make such information available to FinCEN, any other appropriate law enforcement agencies, federal or state regulators, upon request.
We will not notify any person involved in such a transaction that his transaction has been reported, except as permitted by the BSA regulations. We understand that anyone who is subpoenaed or required to disclose a SAR or the information contained in the SAR, except where disclosure is requested by FinCEN, or other appropriate law enforcement or regulatory agency, will decline to produce to the SAR or to provide any information that would disclose that a SAR was prepared or filed. We ensure to notify FinCEN of any such request and our response.
14.2 Currency Transaction Reports (CTR) – $10,000 Threshold:
It is the policy of Greelance Inc. that if we receive currency, we will file with FinCEN CTRs for the transactions involving currency that exceed $10,000. Multiple transactions will be treated as a single transaction if the total is more than $10,000 during any one business day. We will use the FinCEN Form 112 & 8300 to report it at BSA E- Filing.
Our Corporation’s policy is that if a suspicion of money laundering is raised, no further work will be done on the topic that sparked the suspicion. Commercial factors, as well as the difficulties of replying to the Client/Freelancer/Agency/Platform User’s inquiries on the subject, must not take precedence over the Corporation’s legal obligations in this regard.
In such cases, the AML Compliance Officer will move as quickly as possible to allow work to continue or, if necessary, to withdraw from the Client/Freelancer/Agency/Platform User relationship, and will help staff in any related Client/Freelancer/Agency/Platform User conversations.
15.1 Responsibility for maintaining required AML records and filing SARs:
Our AML Compliance Officer and his or her designee will be responsible to ensure that the AML records are maintained properly and that any/all SARs, as required, are filed within the prescribed time.
15.2 SAR Maintenance and Confidentiality:
It is the policy of Greelance Inc. to hold SARs (Suspicious Activity Reports) and any supporting documentation confidential. We will not inform anyone outside the law enforcement or regulatory agency about a SAR. We will refuse any subpoena requests for SARs or SAR information and immediately tell FinCEN of any such subpoena we receive. We will segregate SAR filings and copies of supporting documentation from other Company books and records to avoid disclosing SAR filings.
Our AML Compliance Officer is professionally skilled to handle all subpoenas or other requests for SARs. We will share information with our bank about suspicious transactions in order to determine when a SAR should be filed – unless it would be inappropriate to do so under the circumstances, such as where we file a SAR concerning the bank or its employees.
However, on evaluating internal suspicion reports, the AML Compliance Officer is required to make the formal disclosure of the same to the authorities, as required by law, he will do so by following the proper mechanism.
15.3 Additional Records:
As part of our AML/CFT program, Greelance Inc. will create and maintain SARs, and other relevant documentation on customer identity, verification, funds transfers, and transmittals as well as any records related to customers listed on the OFAC (Office of Foreign Assets Control) list. We will maintain all such SARs and their accompanying documentation for at least five years.
POLICY AND PROCEDURE:
We will work closely with our bankers, Federal and State Enforcement Authorities to detect money laundering. We will exchange the required information, records, data, and exception reports as necessary for compliance with the AML laws. The appropriate notification forms pertaining to Cash Payments over $10,000, Currency Transaction Reports (CTRs), Suspicious Activity Reports (SARs), and Designation of Exempt Persons shall be filed at BSA E-Filing.
Generally, we have agreed that Greelance Inc. will monitor the activities of the customer including proper customer identification information as required.
Greelance Inc. has made several policies that would include adequate screening procedures while recruiting the staff in order to ensure high standards. We have further made policies in order to ensure that the staff being hired is qualified, genuine, and has no past suspicious record of any criminal activity or otherwise. We have developed AML/CFT ongoing employee training under the leadership of the AML Compliance Officer. Such training programs will occur at least on an annual basis.
Greelance Inc. will ensure that AML/CFT program is updated with the latest laws and regulations as amended up to date and will further ensure to amend the policy as per the amendments in the laws related to the AML/CFT program.
Annual testing of our AML/CFT program will be performed. Such annual testing would include an audit of our compliance with the AML/CFT program. The auditor will then issue a report of the auditor’s findings upon the completion of their audit to senior management.
We will address each of the resulting recommendations and report any suspicious transaction through BSA e-filing. If and when regulations governing the reporting of suspicious transactions are changed, we will update our policy to reflect the changes.
The policy of Greelance Inc. will cover the employee money service transactions to the same AML procedures as customer accounts, under the supervision of the AML Compliance Officer.
As part of their yearly performance assessment, we will evaluate the performance of AML supervisors and all employees on a regular basis. A qualified member of the Corporation staff will assess the AML Compliance Officer’s accounts if applicable.
Our Corporation’s policy is that every employee should be on the lookout for signs of money laundering, and should pay attention to and report any complex, unusual, or large transactions, whether completed or not, as well as any unusual patterns of transactions with no apparent economic or legal purpose, and any suspicion for which they believe there are reasonable grounds, according to the Corporation’s procedure.
Every member of the Corporation is expected to pay attention to and report to the AML Compliance Officer :
The level of expectation placed on each individual member of staff in responding to probable suspicions should be commensurate with their position within the company.
Greelance Inc. has reviewed all such areas of its business to identify potential money laundering and terrorist financing risks that could not be covered in the procedures described above and is continually working towards the improvement of its AML/CFT program. The policies and the procedures shall be updated regularly to cover all latest amendments in the Federal and State laws concerning AML/CFT.
I have approved this AML/CFT program as reasonably designed to achieve and monitor the Corporation’s ongoing compliance with the requirements of the BSA, FinCEN, FINRA, USA PATRIOT Act of 2001, and Federal and State Laws (As amended up to date).
Name: Jimmy Idemudia
Date: May 9, 2022