MainGreen Energy A Ltd
Anti-Money Laundering (AML) Program: Compliance and Supervisory Procedures
I. Introduction
This document outlines MainGreen Energy A’s Anti-Money Laundering (AML) Compliance and Supervisory Procedures. We are committed to complying with all applicable US and international AML regulations and preventing financial crime.
II. Compliance Procedures
A. Customer Due Diligence (CDD)
- Customer Identification: We will collect and verify the following information for all customers:
- Full legal name
- Date of birth
- Address (residential and business)
- Government-issued identification documents (valid and unexpired)
- Beneficial Ownership Identification: We will identify and verify the beneficial owners of legal entity customers (companies, trusts). This includes:
- Obtaining ownership structure information (who ultimately owns or controls the entity)
- Verifying the identity of beneficial owners using the same procedures as for individual customers
- Customer Risk Assessment: We will assess the AML risk posed by each customer based on factors such as:
- Industry (higher risk for high-cash businesses, money services)
- Geographical location (countries with higher money laundering risks)
- Source of funds and wealth
- Transaction patterns (large cash transactions, unusual activity)
- Enhanced Due Diligence: We will apply enhanced CDD procedures for higher-risk customers, including:
- Obtaining additional identification documentation
- Verifying the source of funds and wealth
- Conducting more frequent customer reviews
B. Transaction Monitoring
- We will implement a transaction monitoring system to identify suspicious activity that may indicate money laundering or terrorist financing.
- This system will consider:
- Transaction amounts and frequencies compared to customer profile and past activity
- Transactions from high-risk countries or with sanctioned entities
- Complex or layered transactions with no apparent economic purpose
- Large cash transactions
- We will establish transaction thresholds for triggering further scrutiny.
- We will regularly review transaction monitoring reports and investigate suspicious activity.
C. Recordkeeping
- We will maintain comprehensive records of all AML-related activities, including:
- Customer identification data (CDD documents)
- Customer risk assessments
- Transaction monitoring reports and investigations
- Suspicious Activity Reports (SARs) filed with authorities
- Records will be retained for the period mandated by AML regulations (typically 5-10 years).
D. Training
- We will provide ongoing AML training to all relevant personnel, covering:
- AML regulations (US and international)
- CDD procedures (customer identification, beneficial ownership, risk assessment)
- Transaction monitoring red flags
- Reporting suspicious activity
- Training will be tailored to the specific roles and responsibilities of each employee.
E. Reporting
- We will establish procedures for filing SARs with the appropriate authorities (FinCEN in the US, FIU in other countries) when we suspect money laundering or terrorist financing.
- SARs will be filed promptly and accurately, providing all necessary details about the suspicious activity.
F. Sanctions Compliance
- We will maintain an up-to-date list of sanctioned individuals and entities.
- We will screen all customers and transactions against the sanctions list to prevent business relationships with sanctioned parties.
III. Supervisory Procedures
- We will designate a qualified AML Compliance Officer (AMLCO) to oversee the AML program.
- The AMLCO will be responsible for:
- Developing and implementing AML policies and procedures
- Monitoring compliance with AML regulations
- Training employees on AML procedures
- Reviewing and updating the AML program
- Management will provide ongoing oversight of the AML program and ensure its effectiveness.
- We will conduct periodic internal audits to assess the effectiveness of the AML program and identify areas for improvement.
IV. International Considerations
- If MainGreen Energy A operates internationally, we will comply with the AML regulations of each jurisdiction where we do business.
- We will adapt our AML program as necessary to meet the specific requirements of each country.
V. Review and Update
- We will regularly review and update our AML Compliance and Supervisory Procedures to reflect changes in:
- US and international AML regulations
- Our business operations
- AML best practices
- We will maintain documentation of all changes made to the AML program.
VI. Conclusion
MainGreen Energy A is committed to maintaining a robust AML program that effectively detects and prevents money laundering and terrorist financing activity. We will continue to enhance our AML compliance efforts to ensure we remain a responsible corporate citizen.