Anti Money Laundering (AML Policy)

1. Introduction & Purpose

The purpose of this AML Policy is to detect any suspicious or illicit activities and take corrective measures to prevent and control them by applying the necessary techniques and rules defined in this policy. There are set guidelines and procedures in this policy adopted by the Company to detect and prevent money laundering activities by complying with the applicable regulations. This policy ensures that the Company is complying with all the applicable laws & regulations and protecting itself from being used as a channel for any illegal activities.

2. Definitions & Scope

“Speed1, Inc.” hereby referred to as “the Company”. This AML policy applies to all employees, officers and affiliates of the Company. The purpose of this policy is to establish an effective framework for detection and prevention of money laundering activities. Following terms are defined with reference to this policy:

• • Money Laundering: It is the process of hiding the original illegal source of money and converting it to a legal source. This helps criminals to use these money without endangering  their source.
  • Terrorist Financing: It refers to the act of supporting and providing resources to the individuals or groups involved in terrorist activities.
  • Politically Exposed Persons (PEPs): It refers to the prominent position of an individual i.e. whether held in past or holding in present. Due to their influence and power they get involved in money laundering activities and other penal offences such as bribery or corruption. The family and close relatives of PEPs is also considered as PEPs.

3. Regulatory Framework

The Company follows the regulatory framework of FinCEN (Financial Crimes Enforcement Network) and Delaware State laws and regulations regarding AML & KYC. Also, keeping note of the regulations issued by The Bank Secrecy Act (BSA); The USA Patriot Act and other applicable federal state and state laws.

4. Compliance Procedures

The Company follows the following procedures to ensure that the compliance is done in corrective manner:

• Defined Roles: The Board makes the effective implementation of the AML policy by ensuring that all the employees are aware and regularly updated on the same. Proper knowledge and training is provided to the employees so that they can report in a corrective manner if any suspicious activity is detected.
• Compliance Program: A designated individual is appointed as AMLCO (Anti Money Laundering Compliance Officer) who is responsible for compliance and reporting of suspicious activities.
• Internal Control & Policies: The company has standard policies and internal tools by which they regulate the whole framework. Also, the training shall be provided to the respective officers so they understand the framework better.
• Reporting: The duty of AMLCO is to monitor the transaction and file a report if any suspicious activity is detected. The employees or related parties can report to AMLCO if they find anything suspicious.
• Continues Monitoring & Record Keeping: The AMLCO shall record all the relevant transactions and keep the records (specially for large transactions) for the required period of time. The AMLCO is also responsible for continuous monitoring of the transactions of the Company.

5. KYC & CDD

Know Your Customer (KYC) and Customer Due Diligence (CDD) are important tools in reference to the AML policy. This helps in identifying the customers and understanding their business activities which would further help in analyzing whether they fall under the suspicious category or not. The following factors are included for complying with KYC and CDD:

• Verification of ID (Identification Document) of Customer i.e. for both individual and entity;
• Verification of the identity of the Ultimate beneficial Owners (UBOs) in case of entities;
• PEP screening to know if any of the individuals or companies is or are related to any PEP.
• Understanding the nature or business and the products offered by the individual or entity.

6. Risk Assessment

Majorly the following steps are involved in Risk Assessment:

• Transaction monitoring i.e. tracking of financial transactions and identifying the illegal ones.
• Investigation of the suspicious transactions by contacting the customer and reviewing their background and by assessing the overall risk level of the specific customer business or product.
• Reporting of the suspicious activity to the relevant regulatory authority i.e. FinCEN by filing SAR (Suspicious Activity Report). It also includes identifying the products and jurisdictions which fall under the risk category and getting clarifications of the customer operations, if more information is required for risk evaluation.

7. Applicability

Besides the points mentioned in this policy the Company also ensures of the following:

• Periodic audits are conducted to ensure that the AML/KYC programs are effective.
• Customer information is updated from time to time to ensure data accuracy.
• If any suspicious activity is detected then the company shall take the decision at their discretion depending on the severity of the particular case.

8. Updation of Policy

The AML policy will be reviewed periodically and shall be updated time to time as and when required and the changes shall be communicated to the relevant personnel accordingly.