Express Funded LLC (referred to as “the Company,” “we,” or “our”) is committed to maintaining the highest standards in anti-money laundering (AML) compliance and counter-terrorist financing. We adhere to our legal and regulatory obligations to prevent money laundering, terrorist financing, and other illicit financial activities. This policy outlines our responsibilities concerning AML efforts, including verifying client identities, maintaining accurate records, detecting and reporting suspicious activities, and ensuring compliance with sanctions and embargoes.

Scope

This policy applies to all employees, contractors, and external entities working on behalf of Express Funded LLC. It provides foundational standards, based on applicable laws and regulatory frameworks, that must be adhered to universally.

Objectives

The objectives of the AML Policy are to:

1. Protect Express Funded LLC, its employees, and its clients from being used for illegal financial activities, including money laundering and terrorist financing.
2. Establish a clear framework to prevent, detect, and respond to money laundering and terrorist financing risks.

Applicability

Express Funded LLC is required to comply with the relevant AML laws, including but not limited to Ghanaian regulations and other jurisdictions where the company operates. If local laws impose stricter standards than this policy, those local requirements will take precedence. In cases where local laws are less stringent or conflict with this policy, guidance from legal teams will be sought to resolve any issues.

In jurisdictions where this policy cannot be enforced, Express Funded LLC will refrain from engaging in business relationships, and existing relationships may be terminated.

Definition of Money Laundering

Money laundering refers to the process of concealing or disguising the origins of illegally obtained funds, typically through a series of complex transactions. These activities make illicit funds appear legitimate. Money laundering generally occurs in three stages:

1. Placement: Introducing illicit funds into the financial system.
2. Layering: Conducting multiple complex transactions to obscure the origin of the funds.
3. Integration: Reintroducing the laundered money into the economy, making it appear as legally obtained assets.
   
   

These stages may occur simultaneously, making it challenging to detect at various points in the financial system.

Procedure Manual

Client Identification Procedures (KYC Policy)

To prevent money laundering and ensure compliance with regulatory requirements, Express Funded LLC has implemented stringent Know Your Customer (KYC) procedures. All clients must undergo a comprehensive KYC assessment prior to account creation or any financial engagement. This involves collecting and verifying the following information:

• Full Name
• Date of Birth
• Nationality
• Government-issued ID (e.g., Passport, Driver’s License, National ID)
• Proof of Address (e.g., Utility Bill, Bank Statement)

Additional documentation may be required based on local regulatory and tax laws. The KYC process is mandatory before providing clients access to any of the Company’s services or accounts.

Ongoing Monitoring

Express Funded LLC is committed to the continuous monitoring of client accounts and transactions to detect any unusual or suspicious activity. This includes:

• Regularly updating client information.
• Monitoring account transactions for discrepancies or unusual behavior.
• Reassessing high-risk clients and applying enhanced due diligence (EDD) where necessary.

Sanctioned Countries and Prohibited Clients

Express Funded LLC follows strict guidelines regarding business relationships with individuals or entities from sanctioned countries or involved in high-risk activities. The Company will not conduct business with parties engaged in money laundering or terrorist financing. Additionally, we monitor all clients against official sanctions lists, including those issued by governments, international organizations, and regulatory bodies.

Express Funded LLC will not engage in business with individuals or entities in the following countries, which are currently under sanctions:

• Afghanistan
• Burundi
• Central African Republic
• Congo Republic
• Cuba
• Crimea
• Democratic Republic of Congo
• Eritrea
• Guinea
• Guinea-Bissau
• Iran
• Iraq
• Laos
• Liberia
• Libya
• Myanmar
• North Korea
• Papua New Guinea
• Somalia
• South Sudan
• Sudan
• Syria
• Vanuatu
• Venezuela
• Yemen
• Zimbabwe
  
  

Express Funded LLC reserves the right to amend this list in accordance with updates to global sanctions and regulatory requirements.

Reporting and Record Keeping

We are committed to maintaining accurate and complete records of all customer information and financial transactions in compliance with AML and KYC laws. The following steps are part of our reporting and record-keeping process:

• Record Retention: We retain all client identification and transaction records for at least five years, or as required by law.
• Suspicious Activity Reports (SARs): Any suspicious transactions or activities will be reported to the appropriate regulatory authorities. Employees and contractors are required to notify the compliance officer if they detect suspicious behavior.
• Regular Audits: Regular internal and external audits are conducted to ensure compliance with this policy.

Employee Training

All employees of Express Funded LLC are required to undergo regular training on AML and KYC regulations. This training ensures that all staff members are aware of their responsibilities and are equipped to identify suspicious activities, report them appropriately, and prevent non-compliance.

Non-Compliance and Disciplinary Actions

Non-compliance with this AML Policy, whether intentional or unintentional, may result in disciplinary actions, including termination of employment or business relationships. Additionally, non-compliance may lead to legal consequences or regulatory penalties.

Policy Review and Updates

Express Funded LLC is committed to regularly reviewing and updating this policy to reflect changes in laws, regulations, or business practices. All employees are required to stay informed of any changes and comply with updated guidelines.

Contact Information

For any questions or concerns regarding this AML Policy, please contact:

Email: compliance@expressfunded.com
Address:
Express Funded LLC
10-22 Westlands Blvd
West Legon Road
Haatso, Accra
Ghana