GOWEONIT AML POLICY
(Last Updated June 6, 2020)
AML Overview
Anti-Money Laundering (AML) is a critical regulatory process, often lumped in with the KYC process. AML assures that the individual you are transacting with is permitted to do so. Along the same line, AML checks verify that an individual is not on any known bad actor list. These lists are constantly updated and monitored by Goweonit.
Goweonit Anti Money Laundering Policy
Goweonit AML Policy prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022).
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and AML/CFT&P rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. Pursuant to the AML and its implementing regulations, financial institutions are required to make certain searches of their records upon receiving an information request from Office for National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022). Describe Goweonit’s procedures for Office for National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) requests for information on money laundering or terrorist activity.
In order for a firm to obtain information requests from Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022), the firm must first designate an AML Contact Person in GOWEONIT. You should be aware that if you want to change the person who receives Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) requests, you must change the AML contact information in GOWEONIT. When you are faced with a change in personnel who will receive this information, you should be aware that Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) receives a data feed of this revised information from GOWEONIT every other week and that it may take several weeks for a firm’s new AML contact person to receive information from Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022). Therefore, it is advisable for a firm that is aware that a person who had been receiving Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) requests is leaving the firm to change the information on GOWEONIT as soon as practical to ensure continuity of receiving (AML/CFT&P) policy information.
Our AML/CFT&P Requests and Compliance
By using the GOWEONIT Services and app you agree that Goweonit will respond to every Financial Crimes Enforcement Network (Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) ) request concerning accounts and transactions occurred during the use of our service or app by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization in question.
We understand that we have 14 days (unless otherwise specified by Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) from the transmission date of the request to respond to AML/CFT&P Request. We will designate through the AML/CFT&P Contact System (GOWEONIT) one or more persons to be the point of contact (POC) for AML/CFT&Ps and will promptly update the POC information following any change in such information. Unless otherwise stated in the AML/CFT&P or specified by Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022), we are required to search those documents outlined in Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022)’s FAQ. If we find a match, Goweonit will report it to Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) via the Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) ’s Web-based Secure Information Sharing System within 14 days or within the time requested by Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) in the request. If the search parameters differ from those mentioned above (for example, if Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) limits the search to a geographic location), Goweonit will structure our search accordingly.
If Goweonit searches our records and does not find a matching account or transaction, then Goweonit will not reply to the AML/CFT&P. We will maintain documentation that we have performed the required search by [add the details on how yGoweonit will document its searches here. For example, printing a search self-verification document from Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022)’s Secure Information Sharing System confirming that yGoweonit has searched the subject information against your records OR maintaining a log showing the date of the request, the number of accounts searched, the name of the individual conducting the search and a notation of whether or not a match was found].
Goweonit will not disclose the fact that Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) has requested or obtained information from us, except to the extent necessary to comply with the information request. Goweonit will review, maintain and implement procedures to protect the security and confidentiality of requests from Office National Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation (AML/CFT&P) policy – (2019-2022) similar to those procedures established to satisfy the requirements of AML/CFT&P with regard to the protection of customers’ nonpublic information.
We will direct any questions we have about the AML/CFT&P to the requesting federal law enforcement agency as designated in the request. Unless otherwise stated in the AML/CFT&P, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic AML/CFT&P as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.
Customers Who Refuse To Provide Information for AML/CFT&P Request
Goweoniit: If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Letmesent will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Officer will be notified so that we can determine whether we should report the situation to AML/CFT&P
Know Your Customer (KYC)
Know Your Customer (KYC) is a phrase very well known by anyone in a regulated market. This important process allows you to verify that the individual you are dealing with is who they claim. By combining indirect and user provided information, Goweonit is able to assess the largest risk factors in online transactions. User documents are scanned using text and document recognition technology. This instant process allows you to quickly assess who you are dealing with and get down to business.
Verifying Customers Information
Goweonit will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).
We will verify customer identity through documentary means, non-documentary means or both. [Tailor the sentence to your actual situation.] We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means, if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the
• customer’s name,
• street address,
• zip code,
• telephone number (if provided),
• date of birth
• and bank information,
All these information will allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).
Lack Of Verification
Goweonit: When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following:
(1) Not open an account;
(2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity;
(3) Close an account after attempts to verify a customer’s identity fail; and
(4) Determine whether it is necessary to file a complaints in accordance with applicable laws and regulations.
Conducting Ongoing Monitoring to Identify and Report Suspicious Transactions
We will conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers, using the customer risk profile as a baseline against which customer activity is assessed for suspicious transaction reporting.
