Greelance Inc. Anti-Money
Laundering (AML/CFT) Program

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.

POLICY:

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 –

1. Initially, the cash enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, like, money orders or traveler’s checks, or deposited fractionally into accounts at financial institutions.
2. At the “layering stage”, the said converted funds are then transferred or moved into other accounts or other financial institutions, to further separate the money from its criminal origin.
3. At the final “integration” stage, the funds are then reintroduced into the economy which is further used to fund other criminal activities or illegitimate businesses.

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.

PROCEDURE:

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.

POLICY:

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.

PROCEDURE:

1. The Corporation will select an AML/CFT Compliance Officer who will coordinate AML efforts and compliance duties regularly.
2. Any member of staff who suspects or has reason to suspect that any potentially suspicious behavior has occurred or will occur if a transaction is completed must immediately tell the AML/CFT Compliance Officer.
3. Employees are urged to contact the AML/CFT Compliance Officer if they have any queries or concerns about the Greelance Inc. Anti-Money Laundering Policies and Procedures.

AML/CFT Compliance Officer shall perform the following duties:

1. Coordination and monitoring of Greelance Inc.’s day-to-day compliance with applicable anti-money laundering laws and regulations as well as Greelance Inc.’s anti-money laundering policy and procedures;
2. Develop and implement systems, mechanisms, and procedures to ensure that the accountable person’s staff reports any suspicious money laundering or financing of terrorism activity;
3. Overseeing communication and training for employees;
4. Receiving and reviewing the reports of suspicious activity received from the Employees;
5. Responding to both the internal and external queries regarding this document in time;
6. Ensuring that the Corporation is keeping and maintaining all of the required AML records;
7. Ensuring that necessary Suspicious Activity Reports (SARs) are filed properly with the Financial Crimes Enforcement Network (FinCEN) when appropriate/required;
8. Assessing, understanding, and working on the risks arising from doing business;
9. Compliance of Know your customer and customer due diligence (CDD).

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).

POLICY:

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.

PROCEDURE:

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:

POLICY:

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.

PROCEDURE:

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.

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:

• NIC/Passport/Government Identity
• Bank statement, utility bills, including electricity and water bills;
• Information about occupation or employment;
• Employer Identification Number;
• Tax Identification Number;
• Credit Card/Bank Account Information;
• Any Applicable Form (US or Non-US)
• Photograph

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:

• NIC/Passport/Government Identity of the Authorized Person;
• Bank statement, utility bills, including electricity and water bills;
• Employer Identification Number;
• Tax Identification Number;
• Credit Card/Bank Account Information;
• Any Applicable Form (US or Non-US);
• Photograph of Authorized Person;
• Board resolution authorizing the Directors/Principals authority to act;
• Articles of Memorandum and Articles of Association;
• Certificate of Incorporation;
• List of Directors/Members/Partners;
• Authorized signatory list;
• To establish the identity of foreign nationals, entities, local entities, and other bodies, the company must fulfill the identification standards set forth in the Regulations.

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:

1. Any Client/Freelancer/Agency/Platform User who provides the Compliance Officer cause to think that his funds come from, or are routed via, an “offshore bank,” or a bank incorporated or chartered under the laws of a Non-Cooperative Jurisdiction; and the source of his funds may not be legitimate/legal or may aid terrorist activities.
2. A Senior Foreign Political Figure, a member of a Senior Foreign Political Figure’s Immediate Family, or a Senior Foreign Political figure’s close associate;
3. Any Client/Freelancer/Agency/Platform User resident/residing of/in, or organized or chartered under the laws of, a Non-Cooperative Jurisdiction;

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:

1. Assessment of the Client/Freelancer/Agency/Platform User’s business reputation by reviewing the financial or professional references, generally available media reports or by other means;
2. Considering the source of the Client/Freelancer/Agency/Platform User’s wealth, including the economic activities that generated the Client/Freelancer/Agency/Platform User’s wealth, and the source of the particular funds intended to be used to make the investment;
3. Reviewing generally available public information, such as media reports, to determine whether the Client/Freelancer/Agency/Platform User has been the subject of any criminal or civil enforcement action based on violations of AML laws or regulations or any criminal indictment, investigation, conviction or civil enforcement action relating to terrorist funding;
4. Conducting a face-to-face meeting with the Client/Freelancer/Agency/Platform User to discuss/confirm the account opening documents.

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 :

1. Assessment of the Platform User’s business reputation by reviewing the financial or professional references, generally available media reports or by other means;
2. Examining recent changes in the ownership or senior management of the Platform User;
3. Conducting a visit to the Platform User’s place of business and conducting a face-to-face meeting with the Platform User to discuss/confirm the account application, the purpose of the account and the source of assets;
4. Reviewing generally available public information to determine whether the Platform User has been the subject of any criminal or civil enforcement action based on violations of AML laws or regulations or any criminal indictment, investigation, conviction or civil enforcement action relating to financing of terrorists.

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:

• An individual’s unexpired government-issued identity documenting nationality, residency, and bearing a photograph or other security features, such as a driver’s license or passport; and
• For an entity, other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument.

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:

• Contacting a customer;
• Independent verification of the customer’s identity through the comparison of information provided by the customer with the information obtained from a consumer reporting agency, public database, employer, or other sources;
• Checking the references with financial institutions;

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.

7.5       Recordkeeping:

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:

• When such reliance is reasonable under the circumstances;
• When the other financial institutions are subject to a rule implementing the anti-money laundering compliance program requirements of 31 U.S.C. 5318(h), and are regulated by a Federal functional regulator.

POLICY:

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.

PROCEDURE:

• The responsible staff will obtain Know Your Customer (KYC) of Client/Freelancer/Agency/Platform Users;
• To the greatest degree practicable, the Client/Freelancer/Agency/Platform User’s information will be cross-checked for consistency with any publicly available information.
• If the Client/Freelancer/Agency/Platform User’s replies are improbable or contradictory with other evidence, or if the Client/Freelancer/Agency/Platform User refuses to provide sufficient answers to due diligence inquiries, the Corporation’s responsible personnel will consider terminating the User Account.
• The CDD information will be reviewed in connection with, and would provide a baseline for, evaluating customer transactions in order to determine whether the transactions are suspicious and need to be reported.
• Greelance Inc. may perform enhanced due diligence, which are as under;.

Customer Identification Program;

Greelance Inc. has implemented the Customer Identification Program for the Platform Users:

• Customers who open new accounts should have their identities verified.
• Maintain records of information used to verify the customer’s identity, including name, address, and other identifying information.
• Determine whether the person seeking to open an account appears on any government lists of known or suspected terrorist organizations.

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:

• Contacting the customers.
• Checking references with other financial institutions.
• Obtaining a financial statement.

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:

• The type of customer;
• The account or service being offered;
• The customer’s income;
• The customer’s principal occupation or business; and
• In the case of existing customers, the history of customer’s activity.

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.

POLICY:

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.

PROCEDURE:

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:

• The customer showing unusual concern about the Company’s compliance with government reporting requirements and the Corporation’s AML policies (particularly/specifically concerning his or her identity, type of business), or is reluctant to or refuses to reveal any information concerning the business activities, or furnishes unusual or suspicious identification or documents.
• The customer intends to engage in a transaction that lacks commercial sense or is inconsistent with the customer’s declared business.
• The Client/Freelancer/Agency/Platform User’s statement identifying a genuine source of funds is fraudulent, misleading, or materially wrong.
• Upon request, the customer refuses/denies to identify or fails to indicate any legitimate source for his or her funds and other assets.
• The customer (or any person publicly associated with that customer) has a questionable background or is the subject of any kind of news reports indicating possible criminal, civil, or regulatory violations.
• The customer exhibits a lack of concern regarding the transaction costs.
• The customer appears to be operating as an agent for an unnamed principal, but refuses or is hesitant to offer information or is otherwise evasive about that person or entity without genuine commercial reasons.
• The customer has difficulty in describing the nature of his or her business.
• The customer attempts to conduct frequent or large transactions or asks for exemptions from the Company’s AML policies.
• The customer engages in transactions involving cash, currency equivalents, or other monetary instruments that appear to be contrived to avoid the $10,000 government reporting requirements, particularly if the cash or monetary instruments are slightly below the reporting or recording levels.
• For no apparent/valid reason, the customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
• The customer is from or has accounts in, a country identified as a non-cooperative country or territory by the FATF.
• The customer has unexplained/unjustified or a sudden extensive money service activity, especially when they had little or no previous activity.
• The customer has a large number of wire transfers to some unrelated third parties who are not consistent with the customer’s legitimate business purpose.
• The customer has performed a financial activity with no apparent business purpose to or from a country identified as a money laundering risk or a bank secrecy haven.
• The customer makes a funds deposit following an immediate request that the money be wired out or transferred to a third party, or to another Corporation, without any apparent business purpose.
• The customer requests that a transaction be processed to avoid the Company’s normal documentation requirements.
• The customer uses multiple accounts, or maintains certain accounts in the names of family members or corporate entities, with no apparent/reasonable/valid purpose.
• The customer’s inflows of funds or other assets far exceed his or her known income or resources.

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.

POLICY:

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.

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.

POLICY:

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.

 PROCEDURE:

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:

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.

 PROCEDURE:

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:

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.

PROCEDURE:

1. All employees are required :

• To participate in anti-money laundering policies and procedures training sessions at a period set by the AML Compliance Officer.
• To learn how to spot and respond to transactions that could be related to money laundering.
• To escalate and report the situation to the AML Compliance Officer as soon as possible.
• To familiarize themselves with the Anti-Money Laundering Act and Regulations and to follow them.

2. The AML Compliance Officer shall assess alternative AML/CFT training methods in order to make appropriate training activities available to all employees who have Client/Freelancer/Agency/Platform User interaction or access to Client/Freelancer/Agency/Platform User information.
3. The training program will include methods for validating that each individual has attained an appropriate level of knowledge and understanding, such as formal testing, informal conversation, educational booklets, films, intranet systems, in-person lectures, explanatory letters and other methods.
4. The AML Compliance Officer will preserve records of completed training, including test or other evaluation results, to demonstrate that each individual has reached an adequate level of competence.
5. As part of the relevant continuity of the training program, the AML Compliance Officer will analyze the effectiveness of the completed program and update the training information to reflect changes in laws, regulations, guidelines, and practice.

POLICY:

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.

PROCEDURE:

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.

POLICY:

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.

PROCEDURE:

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.

POLICY:

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 :

• Any transaction made on behalf of a person whose identity has not been established.;

And

• Electronic funds transfer that do not contain complete originator information.

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.

PROCEDURE:

• Every employee must be aware of the likelihood that the Corporation’s services could be utilized for money laundering, so he/she should always remain vigilant to detect any criminal or terrorist activity, while on the job.
• When a member of staff becomes aware of a probable suspicion, he/she must acquire relevant information from normal sources and determine if there are reasonable reasons to suspect money laundering. The duty to obtain relevant information does not include conducting research or investigation beyond using readily available information sources within the Corporation.
• If a member of staff is completely satisfied that there are no reasonable grounds for suspicion after acquiring and considering routinely accessible information, no further action should be taken; otherwise, if there are reasonable grounds for suspicion, the staff should inform the AML Compliance Officer about such a Client/Freelancer/Agency/Platform User Account.
• If a member of staff believes there are reasonable grounds to suspect money laundering based on their own observations, he or she must send a suspicion report to the AML Compliance Officer in the manner established by the AML Compliance Officer for that purpose. Such reports will be completely confidential, and the employee will suffer no retaliation for reporting the same. Client/Freelancer/Agency/Platform User confidentiality is not violated by such an internal suspicion report.
• A member of staff who develops or becomes aware of a suspicion of money laundering must not discuss it with any outside parties or other members of staff unless they are directly involved in the situation that is raising concern.
• At no time shall a member of staff reveal a money laundering suspicion to the person suspected, Freelance Inc. Platform User, or to any third party. If circumstances emerge that may make Client/Freelancer/Agency/Platform User interaction difficult, the member of staff must seek and follow the AML Compliance Officer’s directions.

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).