AML Policy

AML Policy

Trade Assistance LLC ("Trade Assistance," "we," "us," or "our") is committed to preventing money laundering, terrorist financing, and other illicit financial activities through its escrow services. We adhere to all applicable Anti-Money Laundering (AML) laws and regulations, including but not limited to the Bank Secrecy Act (BSA) and the USA PATRIOT Act, as overseen by the Financial Crimes Enforcement Network (FinCEN) in the United States.

Our robust AML program is designed to detect, prevent, and report suspicious activities, safeguarding the integrity of our platform and protecting both buyers and sellers from financial crime.

  1. Purpose of this Policy

    This AML Policy outlines the measures Trade Assistance LLC implements to mitigate the risks associated with money laundering and terrorist financing. Our goal is to ensure that our services are not exploited for illegal purposes, thereby fostering a secure and trustworthy environment for all users.

  2. Designated AML Compliance Officer

    Trade Assistance LLC has appointed a dedicated AML Compliance Officer who is responsible for overseeing the implementation and enforcement of this policy. The AML Compliance Officer's duties include:

    • Developing and maintaining the AML program.
    • Ensuring compliance with all relevant AML laws and regulations.
    • Monitoring transactions for suspicious activities.
    • Providing ongoing AML training to all relevant employees.
    • Responding to inquiries from regulatory authorities.
    • Reporting suspicious activities to FinCEN, as required.

  3. Risk-Based Approach

    Trade Assistance LLC employs a risk-based approach to AML, meaning that the intensity of our due diligence and monitoring efforts is commensurate with the level of risk posed by a particular transaction, customer, or geographical area. This allows us to allocate resources effectively, focusing on areas with higher potential for illicit activity.

    Factors influencing our risk assessment include:

    • Customer Risk: Type of customer (individual, business, entity), geographic location, nature of business, and historical transaction patterns.
    • Product/Service Risk: The inherent risk associated with specific types of transactions facilitated by our escrow service (e.g., high-value items, digital assets, cross-border transactions).
    • Geographic Risk: Countries or regions identified by international bodies (e.g., FATF) or national authorities as high-risk for money laundering or terrorist financing.
    • Delivery Channel Risk: The methods used to interact with our platform (e.g., online, mobile).

  4. Customer Due Diligence (CDD) and Know Your Customer (KYC)

    Trade Assistance LLC implements stringent CDD and KYC procedures to verify the identity of all participants in a transaction. This is a crucial first step in preventing money laundering.

    4.1. Identity Verification

    Before any transaction can be initiated, both buyers and sellers will be required to provide verifiable identification information. This may include, but is not limited to:

    • For Individuals: Full legal name, date of birth, residential address, nationality, and a government-issued identification document (e.g., passport, driver's license, national ID card).
    • For Entities/Businesses: Legal business name, registration number, business address, tax identification number, and documentation verifying the legal existence and beneficial ownership of the entity. We will also identify and verify the identity of key individuals associated with the entity (e.g., directors, beneficial owners).

    We utilize reliable, independent sources for verification, which may include electronic verification tools, public databases, and official registries.

    4.2. Enhanced Due Diligence (EDD)

    For higher-risk customers or transactions (identified through our risk assessment), we will apply Enhanced Due Diligence measures. This may involve:

    • Obtaining additional information about the source of funds or wealth.
    • Understanding the purpose and intended nature of the business relationship in greater detail.
    • Conducting more extensive background checks, including screening against sanctions lists (e.g., OFAC), Politically Exposed Persons (PEPs) lists, and adverse media.
    • Requiring additional documentation or verification methods.

    4.3. Ongoing Monitoring

    CDD is not a one-time process. We continuously monitor customer relationships and transactions to ensure that the information we hold remains accurate and consistent with the customer's activity. Any significant changes in a customer's behavior or transaction patterns may trigger further review and, if necessary, EDD.

  5. Transaction Monitoring

    Trade Assistance LLC employs a comprehensive transaction monitoring system to detect unusual or suspicious activities. Our system analyzes transactions in real-time and retrospectively, looking for patterns, anomalies, and red flags that may indicate money laundering or terrorist financing.

    Red flags may include, but are not limited to:

    • Large, unusual, or inconsistent transaction amounts.
    • Frequent transactions just below reporting thresholds.
    • Transactions involving high-risk jurisdictions.
    • Complex transaction structures without a clear economic purpose.
    • Attempts to use multiple accounts or identities for a single transaction.
    • Unwillingness to provide requested information or provide evasive answers.
    • Transactions inconsistent with the customer's stated profile or typical activity.
    • Changes in the nature of transactions without reasonable explanation.

    Our monitoring tools may leverage artificial intelligence and machine learning to improve the efficiency and accuracy of detection.

  6. Suspicious Activity Reporting (SAR)

    If, through our CDD, transaction monitoring, or any other means, Trade Assistance LLC identifies or suspects any activity that may be indicative of money laundering, terrorist financing, or other financial crime, we will promptly file a Suspicious Activity Report (SAR) with FinCEN, as required by law.

    All SAR filings are confidential, and we are prohibited from disclosing the fact of a SAR filing to the subject of the report or any unauthorized third party (tipping-off).

  7. Record Keeping

    Trade Assistance LLC maintains comprehensive records of all customer identification data, transaction records, and any reports filed, in accordance with applicable regulatory requirements. These records are retained for the legally mandated period and are available to regulatory authorities upon request.

  8. Employee Training

    All relevant employees of Trade Assistance LLC receive regular and comprehensive training on AML laws, regulations, internal policies, and procedures. This training ensures that employees understand their responsibilities in detecting and reporting suspicious activities and are equipped to identify red flags. Training is tailored to the specific roles and responsibilities of employees.

  9. Internal Controls and Independent Testing

    Trade Assistance LLC maintains robust internal controls to ensure the effectiveness of our AML program. These controls are subject to independent testing by qualified internal or external parties to assess their adequacy and effectiveness. Any deficiencies identified are promptly addressed.

  10. Compliance with Sanctions

    Trade Assistance LLC is committed to complying with all applicable sanctions programs, including those administered by the Office of Foreign Assets Control (OFAC). We screen all customers and transactions against relevant sanctions lists to prevent engagement with sanctioned individuals, entities, or jurisdictions.

  11. Policy Review

    This AML Policy is subject to regular review and updates to ensure its ongoing effectiveness and compliance with evolving regulatory requirements and industry best practices.

Contact Information

For any questions regarding Trade Assistance LLC's AML Policy, please contact us at: