Anti-Money Laundering Policy

Our commitment to financial crime prevention

Last updated: January 15, 2025

Zero Tolerance Policy

Moniezen has zero tolerance for money laundering, terrorist financing, and other financial crimes. We are committed to maintaining the highest standards of compliance with all applicable laws and regulations.

1. Policy Overview

This Anti-Money Laundering (AML) Policy outlines Moniezen B.V.'s commitment to preventing money laundering, terrorist financing, and other financial crimes. As a licensed payment institution in the Netherlands, we comply with Dutch AML legislation, EU directives, and international standards.

Regulatory Framework

  • Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft)
  • EU 5th Anti-Money Laundering Directive (5AMLD)
  • Financial Action Task Force (FATF) Recommendations
  • EU Payment Services Directive 2 (PSD2)

2. Know Your Customer (KYC) Procedures

Customer Identification

We verify the identity of all customers before providing services. This includes:

  • Individual Customers: Government-issued photo ID, proof of address, date of birth verification
  • Business Customers: Company registration documents, beneficial ownership information, authorized signatory verification
  • Enhanced Due Diligence: Additional documentation for high-risk customers or large transactions

Risk Assessment

We conduct risk assessments based on:

Customer Risk

  • • Identity verification level
  • • Source of funds
  • • Transaction patterns
  • • Professional background

Geographic Risk

  • • High-risk jurisdictions
  • • Sanctions lists
  • • Tax havens
  • • Conflict zones

Product Risk

  • • Transaction amount
  • • Frequency of use
  • • Payment methods
  • • Service complexity

3. Transaction Monitoring

Automated Monitoring Systems

We employ advanced transaction monitoring systems that analyze patterns and flag suspicious activities in real-time:

  • Machine learning algorithms for pattern recognition
  • Real-time sanctions screening
  • Velocity checks and threshold monitoring
  • Geographic and behavioral analysis
  • Integration with global watch lists

Red Flag Indicators

Transactions that may trigger additional review include:

Suspicious Activity Indicators

Transaction Patterns
  • • Unusual transaction amounts
  • • Frequent just-below-threshold transfers
  • • Round number transactions
  • • Rapid sequence of transfers
Customer Behavior
  • • Reluctance to provide information
  • • Inconsistent source of funds
  • • Unusual urgency
  • • Complex routing instructions

4. Sanctions Screening

Comprehensive Sanctions Lists

We screen all customers and transactions against multiple sanctions lists:

International Lists

  • UN Security Council Sanctions
  • US OFAC Sanctions (SDN, SSI)
  • EU Consolidated Sanctions

Specialized Lists

  • PEP (Politically Exposed Persons)
  • World-Check Risk Intelligence
  • Internal Blocked Persons List

5. Suspicious Activity Reporting

Reporting Obligations

We are legally obligated to report suspicious transactions to the Financial Intelligence Unit (FIU-Nederland). Our reporting process includes:

  • Immediate internal escalation of suspicious activities
  • Investigation by our compliance team
  • Filing of Suspicious Activity Reports (SARs) within required timeframes
  • Cooperation with law enforcement investigations
  • Maintenance of detailed records and documentation

Confidentiality Notice

Under Dutch law, we are prohibited from disclosing the fact that a suspicious activity report has been filed. This protects ongoing investigations and prevents tipping off potentially criminal actors.

6. Record Keeping

Document Retention

We maintain comprehensive records in accordance with legal requirements:

Customer Records

  • • Identity verification documents: 5 years
  • • Account opening records: 5 years
  • • Enhanced due diligence files: 10 years

Transaction Records

  • • All transaction data: 5 years
  • • Suspicious activity reports: 10 years
  • • Correspondence records: 5 years

7. Staff Training and Governance

Training Program

All Moniezen employees receive comprehensive AML training:

  • Initial onboarding AML certification
  • Annual refresher training and updates
  • Specialized training for compliance and risk teams
  • Regular updates on regulatory changes

Organizational Structure

AML Governance Team

Chief Compliance Officer
Overall AML program oversight
AML Investigation Team
Transaction monitoring and investigation
Risk Management
Risk assessment and policy development

8. Customer Cooperation

Your Responsibilities

As a Moniezen customer, you play a crucial role in our AML efforts:

  • Provide accurate and complete information during registration
  • Update your profile when circumstances change
  • Respond promptly to requests for additional documentation
  • Report any unauthorized use of your account
  • Use our services only for legitimate purposes

Thank You for Your Cooperation

Your compliance with our AML requirements helps protect the integrity of the global financial system and ensures we can continue providing secure money transfer services.

9. Contact Information

AML Compliance Team

Email: compliance@moniezen.com

Phone: +31 20 123 4567

Address:
Moniezen B.V.
Compliance Department
Herengracht 124
1015 BT Amsterdam
Netherlands