Anti-Money Laundering (AML) Policy

1. Overview

Easner, Inc. ("Easner," "we," "us," or "our") is committed to preventing money laundering, terrorist financing, and other financial crimes. As a technology platform facilitating financial services through licensed partners, we maintain a comprehensive Anti-Money Laundering (AML) program designed to detect, prevent, and report suspicious activities in accordance with applicable laws and regulations.

This policy outlines our AML procedures, controls, and obligations. We conduct AML screening and monitoring on all users and transactions. For information about our identity verification procedures, please review our KYC/KYB Policy.

2. What is Anti-Money Laundering (AML)?

Anti-Money Laundering (AML) refers to a set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. Money laundering involves three stages: placement (introducing illegal funds into the financial system), layering (concealing the source of funds through complex transactions), and integration (making the funds appear legitimate).

AML regulations require financial service providers to implement controls to detect and prevent money laundering activities, conduct customer due diligence, monitor transactions, and report suspicious activities to relevant authorities.

3. Our AML Program

Easner maintains a comprehensive AML program that includes:

• Customer Due Diligence (CDD): We verify the identity of all users through our KYC procedures (see our KYC/KYB Policy)
• Enhanced Due Diligence (EDD): We conduct enhanced screening for higher-risk customers, including PEPs (Politically Exposed Persons), customers from high-risk jurisdictions, and customers with unusual transaction patterns
• Sanctions Screening: We screen all users and transactions against international sanctions lists, including OFAC, UN, EU, and other relevant sanctions regimes
• Transaction Monitoring: We monitor all transactions in real-time for suspicious patterns, unusual activity, and potential money laundering indicators
• Suspicious Activity Reporting: We file Suspicious Activity Reports (SARs) with relevant authorities when we identify potentially suspicious transactions
• Ongoing Monitoring: We continuously monitor customer relationships and transactions for changes in risk profile or suspicious behavior
• Record Keeping: We maintain comprehensive records of all transactions and customer information as required by law
• Training and Compliance: Our team receives regular training on AML regulations and procedures

4. Customer Due Diligence

We conduct customer due diligence on all users, which includes:

• Identity verification through our KYC procedures
• Verification of beneficial owners for business customers
• Assessment of customer risk profile
• Understanding the nature and purpose of the customer relationship
• Ongoing monitoring of transactions and account activity

For higher-risk customers, we conduct Enhanced Due Diligence (EDD), which may include additional verification, source of funds verification, and more frequent monitoring.

5. Sanctions Screening

We screen all users and transactions against international sanctions lists, including but not limited to:

• Office of Foreign Assets Control (OFAC) sanctions (United States)
• United Nations Security Council sanctions
• European Union sanctions
• United Kingdom sanctions
• Other relevant sanctions regimes based on jurisdiction and transaction corridors

We do not process transactions for individuals, entities, or countries subject to sanctions. If a match is identified during screening, we will block the transaction and may be required to report it to relevant authorities.

6. Transaction Monitoring

We monitor all transactions in real-time for indicators of suspicious activity, including:

• Transactions that are unusually large or frequent
• Transactions that appear to be structured to avoid reporting thresholds
• Transactions involving high-risk jurisdictions
• Transactions with no apparent economic or lawful purpose
• Rapid movement of funds through multiple accounts
• Transactions inconsistent with the customer's known profile or business
• Transactions involving parties on sanctions lists or with adverse media
• Unusual patterns of transactions that may indicate layering

Our automated monitoring systems flag potentially suspicious transactions for review by our compliance team. All flagged transactions undergo manual review and investigation.

7. Suspicious Activity Reporting

When we identify potentially suspicious activity, we are required by law to file a Suspicious Activity Report (SAR) or similar report with the relevant financial intelligence unit or regulatory authority. We may be required to file reports in multiple jurisdictions depending on the nature of the activity and the jurisdictions involved.

Important: We are prohibited by law from informing you if we have filed a SAR or are investigating suspicious activity. This is to prevent "tipping off" and to protect the integrity of investigations.

8. Risk-Based Approach

We employ a risk-based approach to AML compliance, meaning we apply more stringent controls to higher-risk customers and transactions. Risk factors we consider include:

• Customer Risk: PEP status, adverse media, sanctions exposure, country of residence, business type
• Transaction Risk: Transaction amount, frequency, destination country, currency pair, transaction pattern
• Product Risk: Complexity of the service, anonymity features, speed of settlement
• Geographic Risk: Countries with weak AML controls, high levels of corruption, or subject to sanctions

Higher-risk customers and transactions receive enhanced due diligence, more frequent monitoring, and may be subject to additional controls or restrictions.

9. User Obligations

As a user of Easner services, you have certain obligations under AML regulations:

• Provide Accurate Information: You must provide accurate, complete, and truthful information about yourself, your transactions, and the source of your funds
• Cooperate with Verification: You must cooperate with our KYC/KYB and AML verification procedures
• Report Changes: You must notify us immediately of any changes to your information or circumstances that may affect your risk profile
• Use Services Legitimately: You must use our services only for legitimate purposes and not for money laundering, terrorist financing, or other illegal activities
• Understand Restrictions: You must understand that we may restrict or refuse transactions that we believe may be suspicious or violate AML regulations

Consequences of Non-Compliance: Failure to comply with AML obligations may result in account restrictions, transaction delays or refusals, account closure, and reporting to regulatory authorities. Providing false or misleading information may also result in criminal prosecution.

10. Transaction Limits and Restrictions

We may impose transaction limits or restrictions based on AML risk factors, including:

• Daily, weekly, or monthly transaction limits based on verification level and risk profile
• Restrictions on transactions to or from high-risk jurisdictions
• Additional verification requirements for large transactions
• Temporary holds on transactions pending compliance review
• Refusal of transactions that we believe may violate AML regulations

These limits and restrictions are designed to manage AML risk and comply with regulatory requirements. We will notify you of any applicable limits or restrictions that affect your account.

11. Cooperation with Authorities

We cooperate fully with regulatory authorities, law enforcement, and financial intelligence units in the fight against money laundering and terrorist financing. This includes:

• Filing Suspicious Activity Reports and other required disclosures
• Responding to information requests from regulatory authorities
• Providing information in response to court orders and legal processes
• Cooperating with investigations into financial crimes
• Maintaining records as required for regulatory examinations

We may be required to share information with authorities in multiple jurisdictions, depending on the nature of the activity and applicable laws.

12. Record Keeping

We maintain comprehensive records of all transactions, customer information, and AML activities as required by law. Retention periods vary by jurisdiction but typically range from 5 to 7 years after the closure of an account or the last transaction. In some cases, we may be required to retain records for longer periods. All records are maintained securely and in accordance with applicable data protection laws.

13. Training and Compliance

Our compliance team receives regular training on AML regulations, procedures, and emerging threats. We conduct regular reviews and audits of our AML program to ensure effectiveness and compliance with evolving regulatory requirements. We also work closely with our licensed financial service partners to ensure consistent AML standards across our network.

14. Changes to This Policy

We may update this AML Policy from time to time to reflect changes in regulations, our practices, or emerging threats. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Continued use of our services after changes constitutes acceptance of the updated policy.

15. Contact Us

If you have questions about our AML procedures, need to report concerns, or wish to understand how AML requirements affect your account, please contact us at: