AML & ATF Policy

Overview

Malum is committed to the highest standards of Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) compliance. This policy applies to all merchants, buyers, and users of the Malum platform, and sets out the measures we take to detect, prevent, and report suspicious activity.

What is Money Laundering?

Money laundering is the process by which the proceeds of criminal activity are disguised to make them appear to come from a legitimate source. It typically involves three stages: placement (introducing illicit funds into the financial system), layering (concealing the trail through a series of transactions), and integration (reintroducing funds into the economy as apparently legitimate).

What is Terrorist Financing?

Terrorist financing involves providing or collecting funds with the intention that they be used, in full or in part, to carry out terrorist acts, by terrorist organisations, or by individual terrorists. Unlike money laundering, the funds involved may originate from legitimate sources.

Our Obligations

Malum takes the following steps to comply with AML and ATF regulations:

• Monitoring transactions for unusual patterns or activity that may indicate money laundering or terrorist financing.
• Maintaining records of all transactions and customer information as required by applicable law.
• Reporting suspicious activity to the relevant authorities where required.
• Training our team to identify and escalate potential AML and ATF concerns.
• Refusing to process transactions that we reasonably suspect are connected to criminal activity.

Prohibited Activities

The following activities are strictly prohibited on the Malum platform:

• Using Malum to launder money or conceal the proceeds of any criminal activity.
• Processing payments intended to finance terrorism or any designated terrorist organisation.
• Structuring transactions to avoid reporting thresholds (known as "smurfing").
• Providing false or misleading information during account creation or transaction processing.
• Using third-party accounts or identities to obscure the true origin or destination of funds.

Suspicious Activity

Malum may suspend or terminate access to the platform and report to the relevant financial intelligence unit or law enforcement agency if we identify transactions or behaviour consistent with money laundering or terrorist financing. This includes, but is not limited to:

• Unusually large or frequent transactions inconsistent with a merchant's stated business.
• Transactions with no apparent commercial purpose.
• Requests to split transactions to avoid reporting limits.
• Customers or merchants appearing on international sanctions lists.

Sanctions Compliance

Malum screens all users and transactions against applicable sanctions lists, including those maintained by the UN, EU, OFAC, and other relevant authorities. Any match will result in immediate suspension of the account and a report to the appropriate authority.

Record Keeping

We retain transaction records, customer identification data, and any suspicious activity reports for a minimum of five years, or longer where required by applicable law.

Questions & Reporting

If you have concerns about potential AML or ATF activity on our platform, or if you have questions about this policy, please contact us at [email protected]. All reports are treated with strict confidentiality.

Last modified 05/05/2024