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Anti-Money Laundering Policy

Our commitment to preventing money laundering and financial crimes.

Last updated: 2023-01-01

Last Updated: January 1st, 2024

1. Introduction

1.1. Lender Borrower Exchange ("LBEX," "we," "our," or "us") is committed to upholding the highest standards of integrity and diligence in preventing money laundering and financial crimes.
1.2. This AML Policy is a central component of our risk management strategy, designed to ensure compliance with all applicable laws and regulations concerning anti-money laundering.

2. Policy Statement

2.1. LBEX adheres to strict anti-money laundering laws and regulations. This policy sets forth our commitment to detect, prevent, and report potential money laundering or terrorist financing activities.

3. Know Your Customer (KYC) and Customer Due Diligence (CDD)

3.1. We employ robust KYC and CDD procedures to accurately identify and verify the identity of our customers.
3.2. Enhanced Due Diligence (EDD) processes are implemented for high-risk customers, including thorough background checks and continuous monitoring.

4. AML Compliance Structure

4.1. Our AML compliance program is overseen by trained personnel responsible for monitoring and managing AML risks.
4.2. AML compliance responsibilities include keeping up-to-date with AML legislation, monitoring transactions, and reporting suspicious activities to appropriate authorities.

5. Employee Training and Vigilance

5.1. All employees receive comprehensive training on AML policies and procedures, focusing on recognizing and reporting suspicious activities.
5.2. Continuous education and communication ensure staff awareness of evolving AML threats and legislative changes.

6. Monitoring and Reporting of Suspicious Activities

6.1. Continuous transaction monitoring systems are in place to detect unusual or suspicious transaction patterns indicative of money laundering or terrorist financing.
6.2. Any suspicious activities are promptly investigated and reported to the relevant authorities in accordance with legal and regulatory requirements.

7. Record-Keeping Procedures

7.1. We maintain detailed records of all transactions, customer identification documents, and AML monitoring activities for a period as mandated by applicable law.

8. Risk Management and Compliance

8.1. Regular risk assessments are conducted to identify, assess, and manage money laundering risks associated with our products and services.
8.2. Risk mitigation strategies and controls are reviewed and updated regularly to effectively manage identified risks.

9. Third-Party and New Technologies

9.1. We conduct due diligence on all third-party service providers to ensure their compliance with our AML standards.
9.2. Adoption of new technologies for AML purposes is critically evaluated for compliance effectiveness.

10. Internal Audits and Reviews

10.1. Our AML policies and practices are subject to periodic internal audits to ensure compliance with regulatory standards and operational effectiveness.
10.2. Audit findings and recommendations are addressed promptly to continually enhance our AML framework.

11. Regulatory Compliance

11.1. We stay informed of and responsive to changes in AML regulations, adjusting our policies and procedures to remain compliant.

12. Contact Information

12.1. For any inquiries related to our AML policy, please reach out to our compliance department at contact@lbex.us.