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Counter Terrorism Financing Policy

Our commitment to preventing money laundering and financial crimes.

Last updated: 2024-01-01

Last Updated: January 1st, 2024

1. Introduction

1.1. Lender Borrower Exchange ("LBEX," "we," "our," or "us") is committed to the global fight against terrorism and the financing of terrorist activities. This Counter-Terrorism Financing (CTF) Policy outlines our commitment to preventing our services from being used for any activities related to terrorism financing.

2. Policy Statement

2.1. LBEX adheres to strict laws and regulations designed to combat the financing of terrorism. This policy is an integral part of our risk management and compliance program, aiming to identify, prevent, and report any activities that may be related to the financing of terrorism.

3. Risk Assessment

3.1. We conduct regular risk assessments to identify potential risks of terrorism financing within our operations and take appropriate measures to mitigate identified risks.

4. Customer Due Diligence (CDD)

4.1. Robust Customer Due Diligence procedures are implemented for all customers, with Enhanced Due Diligence (EDD) for those posing higher risks.
4.2. Measures include verifying customer identities, understanding the nature of their activities, and assessing their risk profile.

5. Transaction Monitoring

5.1. Continuous monitoring systems are in place to detect unusual or suspicious transaction patterns that may indicate terrorism financing.
5.2. Suspicious transactions are investigated promptly and reported to relevant authorities as required.

6. Reporting Procedures

6.1. In cases of suspected or confirmed financing of terrorism, we will report immediately to the appropriate regulatory and law enforcement authorities as per legal obligations.

7. Employee Training and Awareness

7.1. Regular training is provided to all employees to recognize and respond to potential terrorism financing activities.
7.2. Employees are educated about this policy, relevant laws and regulations, and their responsibilities under these frameworks.

8. Record Keeping

8.1. We maintain comprehensive records of customer identification, transactions, and CDD documentation for the period specified by applicable laws and regulations.

9. Policy Review and Update

9.1. This policy is reviewed regularly and updated as necessary to reflect changes in law, regulation, and our business operations.

10. Senior Management Responsibility

10.1. Our senior management is committed to ensuring the effective implementation of this CTF policy and provides adequate resources for its enforcement.

11. Compliance and Auditing

11.1. Regular audits are conducted to evaluate the effectiveness of our CTF measures. Any identified deficiencies are addressed promptly.

12. Commitment to International Standards

12.1. LBEX is committed to complying with international standards and best practices related to the prevention of terrorism financing, including adherence to recommendations by the Financial Action Task Force (FATF).

13. Contact Information

13.1. For any inquiries related to our CTF policy, please reach out to our compliance department at AML@LBEX.us.