Last updated: January 03, 2021

Sunsoft Digital Limited Anti-Money Laundering (AML) Program Overview

Astripay being owned by Sunsoft Digital Limited is therefore covered by Sunsoft Digital Limited AML policy. Sunsoft Digital Limited is required to establish an Anti-Money Laundering Program (AML) that at a minimum will:

1. Develop internal policies, procedures, and controls

In accordance with the Government’s requirement that all companies implement an Anti-Money Laundering program Sunsoft Digital Limited has adopted a program policy, procedures and controls document.

2. Designate a compliance officer who will be responsible for ensuring that:

  • A. The Sunsoft Digital Limited’s AML Program is implemented effectively, including monitoring compliance by the company with their obligations under the program;
  • B. The AML Program is updated, as necessary; and,
  • C. Appropriate persons are educated and properly trained.

3. Offer ongoing employee training program

Sunsoft Digital Limited will provide its staff ongoing training opportunities in-house or through appropriate third-party training services.

4. Establish Independent audit function to test for compliance

Provide for independent testing to monitor and maintain an adequate AML program.

I. Sunsoft Digital Limited Anti-Money Laundering (AML) Policy Statement

It is the policy of Sunsoft Digital Limited to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorists or criminal activity.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages:

Cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions.

Funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.

Funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes. Because Sunsoft Digital Limited processes financial transactions with customers, there is a very small but real risk of criminal activity through the purchase of assets in the form of houses or other assets.

II. AML Compliance Officer Designation and Duties

As required Sunsoft Digital Limited designates Gerald Akhidenor as the Anti-Money Laundering Program Compliance Officer (AMLCO), with full responsibility for Sunsoft Digital Limited’s anti-money laundering (AML) program. The AMLCO will ensure:

  • D. Sunsoft Digital Limited,s AML Program is implemented effectively, including monitoring compliance by the (Sunsoft Digital Limited’s officers, customers and employees with their obligations under the program;
  • E. The AML Program is updated, as necessary; and,
  • F. Appropriate persons are educated and properly trained.

III. Sharing AML Information with Federal Law Enforcement Agencies

Sunsoft Digital Limited will respond to any requests from the Government Law Enforcement Agencies about accounts or transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization named in the request. Upon receiving an information request, the AMLCO is to be responsible for responding to the request and similar requests in the future. Unless otherwise stated in the request, we are required to search current accounts and transactions, accounts maintained by a named suspect during the preceding 12 months, and transactions conducted by or on behalf of or with a named subject during the preceding six months. If we find a match, we will report it to the authorities involved in a timely manner. If we search our records and do not uncover a matching account or transaction, then we will act according to the law.

IV. Applicant Identification and Verification

We have established, documented, and maintained an electronic Applicant Identification Process. We will collect certain minimum applicant identification information from each applicant and provide notice to applicants that we will seek identification information and compare applicant identification information with government-provided lists of suspected terrorists as mentioned above in Section III.

A. Required Applicant Information

Prior to approving a registration on our website or digital platform, we will collect the following information for all applicants: the name; a valid means of identification bearing a photograph and a bank account or other similar. We will not approve an application in the event that an applicant has failed to fully comply with our KYC verification policy.

B. Applicants Who Refuse To Provide Information

If a potential or existing applicant either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, Sunsoft Digital Limited will reject the application. In either case, our AML Compliance Officer will be notified so that we can determine whether we should report the situation to government agencies or not.

C. Verification of Information

Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our applicants. In verifying applicant identity, we will analyze any logical inconsistencies in the information we obtain.

We will verify applicant identity through documentary evidence, non-documentary evidence, or both. We will use documents to verify applicant identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever possible. We may also use such non-documentary means, after using documentary evidence, if we are still uncertain about whether we know the true identity of the applicant. In analyzing the verification information, we will consider whether there is a logical consistency among the identifying information provided, such as the applicant's name, street address, telephone number (if provided), date of birth, and identification number.

Appropriate documents for verifying the identity of applicants include, but are not limited to, the following:

  • For an individual, an unexpired government-issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver's license, national identification document, voter’s card or passport;
  • We understand that we are not required to take steps to determine whether the document that the applicant has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of an applicant’s identity. However, if we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the applicant's true identity.

We may use any or all of following non-documentary methods of verifying identity:

  • Contacting an applicant;
  • Independently verifying the applicant's identity through the comparison of information provided by the applicant with information obtained from a consumer reporting agency, public database, employer or other source;
  • Checking account numbers with financial institutions via API;

We will use non-documentary methods of verification in the following situations: (1) when the applicant is unable to present an unexpired government-issued identification document with a photograph or other similar safeguard; (2) when we are unfamiliar with the documents the applicant presents for identification verification; (3) when there are other circumstances that increase the risk that we will be unable to verify the true identity of the applicant through documentary means.

D. Record keeping

We will maintain records of all identification information and verification information obtained for five years after the application is received.

E. Notice to Applicants

We will provide notice to applicants that we are requesting information from them to verify their identities, as required by Federal law. We will give notice to applicants regarding the policy either verbally or as a plainly posted notice such as:

To help the government fight the funding of terrorism and money laundering activities, Federal law requires us to obtain, verify, and record information that identifies each person who applies for financial services from The Fuller Center for Housing. We will ask for your name, address and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

V. Monitoring Accounts for Suspicious Activity

1. Detecting Red Flags: Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

  • The applicant exhibits unusual concerns about our compliance with government reporting requirements and Sunsoft Digital Limited AML policies or is reluctant or refuses to reveal any information concerning personal finances, or furnishes unusual or suspicious identification or documents.
  • The information provided by the applicant that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
  • Upon request, the applicant refuses to identify or fails to indicate any legitimate source for his or her funds and other assets when making large transactions.
  • The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
  • The customer exhibits a lack of concern regarding transaction costs.
  • The customer has difficulty describing the nature of his or her business.
  • The customer makes unexplained or sudden large transaction involving cash or cash equivalents or other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds (for example $9,950 early cash payment on the loan)
  • The customer requests that a transaction be processed to avoid our normal documentation requirements.
  • The customer has inflows of funds or other assets well beyond the known income or resources of the applicant.
  • 2. Responding to Red Flags and Suspicious Activity

    When a member of Sunsoft Digital Limited detects any red flag, he or she will investigate further under the direction of the AML Compliance Officer. This may include gathering additional information internally or from third-party sources, contacting the government. The company is obligated to report suspicious transactions that are conducted or attempted by, at or through a loan or finance company and involve or aggregate at least $5,000 in funds or other assets. Suspicious Activity Report (SAR) reports will be filed no later than 30 days after initial detection.

    VI. AML Record Keeping

    A. SAR Maintenance and Confidentiality

    We will hold SAR and any supporting documentation confidential. We will not inform anyone outside of a law enforcement or regulatory agency about a SAR.

    B. Responsibility for AML Records and SAR Filing

    Our AML Compliance Officer and his or her designee will be responsible to ensure that AML records are maintained properly and that any SARs are filed as required.

    C. Records Required

    As part of our AML program, we will create and maintain SAR and other relevant documentation on applicant identity and verification and fund transfers and transmittals as well as any records related to applicants listed on the OFAC list. We will maintain SAR and their accompanying documentation for at least five years.

    VII. Training Programs

    Sunsoft Digital Limited will provide its staff members ongoing training opportunities internally or through appropriate third-party training services.

    We will review our operations to see if certain officers or employees require specialized additional training. Our written procedures will be updated to reflect any such changes.

    VIII. Program to Test AML Program

    Annual testing of our AML program will be performed either by qualified independent third party or internally by a qualified officer. The annual testing will include an audit of our compliance with our AML program.

    The auditor will issue a report of the findings upon completion of their audit to the Board. We will address each of the resulting recommendations.

    IX. Monitoring Employee Conduct and Accounts

    We will subject employee money service transactions to the same AML procedures as customer accounts, under the supervision of the AML Compliance Officer. The AML Compliance Officer's accounts will be reviewed by a qualified member of the company.

    X. Confidential Reporting of AML Non-Compliance

    Employees will report any violations of the firm's AML compliance program to the AML Compliance Officer, unless the violations implicate the Compliance Officer, in which case the employee shall report to an appropriate member of senior management. Such reports will be confidential, and the employee will suffer no retaliation for making them.

    XI. Additional Areas of Risk

    Sunsoft Digital Limited has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above and is continually working to improve its AML program.