AML Policy

Anti-Money Laundering (AML) Policy of MAABS Trading LLC

Effective Date: 05/01/2024

MAABS Trading LLC (referred to as “the Company”) is committed to complying with all applicable laws and regulations aimed at preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines the procedures and controls we have in place to ensure compliance with the U.S. Bank Secrecy Act (BSA), the USA PATRIOT Act, and other relevant laws.

1. Purpose

The purpose of this AML Policy is to ensure that MAABS Trading LLC has adequate internal controls to detect, prevent, and report any activities related to money laundering or terrorist financing. This policy applies to all employees, officers, and agents of MAABS Trading LLC and extends to all products and services offered by the Company.

2. Definition of Money Laundering

Money laundering refers to the process by which individuals or entities attempt to conceal the origin of illicit funds, typically through a series of complex financial transactions. The aim is to make illegally obtained money appear legitimate.

The three stages of money laundering are:

Placement: Introducing illicit funds into the financial system.

Layering: Moving funds through a series of financial transactions to obscure the original source.
Integration: Reintroducing the now “clean” funds into the legitimate economy.

3. Regulatory Framework

MAABS Trading LLC operates in accordance with the following U.S. AML laws and regulations:

The Bank Secrecy Act (BSA): Imposes requirements on financial institutions to keep records and file reports that are useful for detecting and preventing money laundering.

The USA PATRIOT Act: Strengthens measures to prevent, detect, and prosecute money laundering and terrorist financing.
Wyoming State Law: MAABS Trading LLC adheres to state-specific AML requirements and operates in full compliance with Wyoming regulations.

4. AML Compliance Officer

- Reporting any suspicious activity to relevant authorities, including the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).
  The Company has designated an AML Compliance Officer responsible for overseeing the implementation of the AML Policy. The responsibilities of the AML Compliance Officer include:
  - Ensuring compliance with all AML laws and regulations.
  - Developing and implementing internal controls for the detection and reporting of suspicious activity.
  - Conducting employee training on AML requirements.
  - Serving as the point of contact for all AML-related inquiries and audits.

5. Customer Identification Program (CIP)

- Enhanced Due Diligence (EDD): Additional scrutiny will be applied to customers or transactions that pose a higher risk of money laundering, including those involving politically exposed persons (PEPs), high-risk countries, or large, complex transactions.
  As part of our AML procedures, MAABS Trading LLC has established a Customer Identification Program (CIP) that mandates the collection of certain information from customers before establishing a business relationship.
  - Required Information:
  - Full name.
  - Address (residential or business).
  - Date of birth (for individuals).
  - Government-issued identification (e.g., passport, driver’s license).
  - Social Security number (SSN) or Tax Identification Number (TIN).
  - For businesses: business license, articles of incorporation, and beneficial ownership information.

6. Monitoring and Reporting of Suspicious Activity

MAABS Trading LLC will continuously monitor transactions for signs of suspicious activity, including but not limited to:
- Unusual or large transactions that do not appear to have a legitimate purpose.
- Transactions involving high-risk jurisdictions or unverified customers.
- Attempts to evade reporting thresholds or structuring transactions to avoid record-keeping requirements.
Suspicious Activity Reports (SARs):
Any suspicious activity will be reported through a Suspicious Activity Report (SAR) filed with FinCEN. Employees are required to notify the AML Compliance Officer of any suspicious activity, and the Officer will assess whether a SAR needs to be filed.

7. Record Keeping

MAABS Trading LLC will retain all records related to customer identification, transactions, and the filing of SARs in compliance with U.S. law. The following records must be retained for at least five years from the date of the transaction or the end of the customer relationship:

Customer identification documents.

Transaction records, including receipts and invoices.

Any communications relating to suspicious activities.
Copies of all SARs and supporting documentation.

8. Employee Training

All employees of MAABS Trading LLC will undergo regular AML training, which will cover:

The legal framework of AML regulations.

How to recognize and report suspicious activity.

The Company’s internal policies and procedures related to AML compliance.

Training will be conducted on an annual basis and will be updated as necessary to reflect changes in AML laws or Company policy.

9. Penalties for Non-Compliance

Failure to comply with AML laws can result in severe penalties for both MAABS Trading LLC and its employees. Penalties for non-compliance may include:

Fines or criminal penalties.

Loss of operating licenses.

Civil penalties imposed by regulatory bodies.

Damage to the Company’s reputation and customer trust.

All employees are expected to comply fully with the Company’s AML policies. Any employee found to be in violation may face disciplinary action, up to and including termination.

10. Independent Audits

To ensure the effectiveness of the AML program, MAABS Trading LLC will engage in regular independent audits of its AML controls and procedures. These audits will assess:

The effectiveness of the AML program.

Compliance with relevant laws and regulations.
Areas for improvement and necessary corrective actions.

11. Reporting to Authorities

MAABS Trading LLC will fully cooperate with all relevant authorities, including:

FinCEN: For SAR filings and reporting.
The Internal Revenue Service (IRS): For transactions involving cash or cash equivalents exceeding $10,000, a Currency Transaction Report (CTR) will be filed.

12. Amendments to the Policy

This AML Policy may be updated or amended as necessary to reflect changes in applicable laws, regulations, or Company procedures. All updates will be communicated to employees, and revised versions of the policy will be distributed.

13. Contact Information

For any questions related to this AML Policy, please contact the AML Compliance Officer at:

Email: compliance@maabtrade.com

Phone: +1 (630) 518-2463
Address: 866 Crimson Ct, Prospect Heights, IL, 60070