AML

PANDORA REWARDS LLC.ANTI-MONEY LAUNDERING (AML) POLICY
Effective Date: 9/29/2019
Last Revised: 9/29/2024
Reviewed By: Compliance
‍Policy Statement
‍Pandora Rewards LLC is committed to ensuring full compliance with all applicable laws, regulations, and standards regarding Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). This policy outlines the responsibilities and procedures designed to prevent and detect money laundering activities within our operations. Objectives The primary objectives of this AML policy are to: Prevent Pandora Rewards LLC from being used, intentionally or unintentionally, for     money laundering or terrorist financing activities. Ensure     compliance with applicable laws and regulations, including the Bank Secrecy Act (BSA) and the USA PATRIOT Act. Establish a framework for identifying, assessing, and mitigating money laundering risks. Provide     guidelines for reporting suspicious activities to the appropriate authorities.
‍Scope
‍This policy applies to all employees, directors, and officers of Pandora Rewards LLC., as well as third-party vendors and partners conducting business on behalf of the company. All must adhere to this policy in the course of performing their duties and responsibilities.
Definitions Money Laundering: The process of disguising the proceeds of illegal activities as legitimate funds. Terrorist Financing: The use of funds to support terrorist activities.
Suspicious Activity: Any transaction or behavior that raises red flags regarding the legitimacy of a client or source of funds. Roles and Responsibilities Board of Directors and Senior Management: Ensure that an effective AML program is implemented and maintained. Allocate adequate resources to ensure compliance with AML obligations. Oversee the training and education of employees regarding AML responsibilities.  AML     Compliance Officer:   Appointed by senior management, the Compliance Officer is responsible for      day-to-day oversight of the AML program.  The officer must ensure proper implementation of internal controls, ongoing training, risk assessment, and reporting of suspicious activities.  
‍Employees: Employees must be vigilant and report any suspicious activity to the AML Compliance Officer.  Complete mandatory AML training annually to remain informed of compliance responsibilities.
‍AML Program Components Customer Due Diligence (CDD) and Know Your Customer (KYC): Verify the identity of all new clients before entering into a business relationship. Conduct ongoing monitoring of clients and their transactions to detect suspicious patterns.  Ensure that customer records are updated and that high-risk clients are      identified and managed according to stricter scrutiny.  
‍Risk Assessment: Regularly assess the company’s exposure to money laundering risks.  Ensure that high-risk areas, customers, and transactions are identified and mitigated.  
‍Transaction Monitoring:   Implement monitoring systems to detect suspicious transactions.  Flag      and review large or unusual transactions that may indicate money laundering or terrorist financing.  
‍Suspicious Activity Reporting (SAR): Employees must report any suspicious transactions or behavior to the AML Compliance Officer.  The Compliance Officer will determine whether to file a Suspicious Activity      Report (SAR) with the Financial Crimes Enforcement Network (FinCEN).  
‍Record-Keeping:   Maintain  records of all transactions, customer information, and due diligence      documents for a minimum of five years.  Ensure      that records are available for review by regulators and auditors.  
‍Training and Awareness:   Provide      regular AML training to all employees, tailored to their roles and      responsibilities.  Ensure      that new employees complete AML training within 30 days of hire. Reporting Procedures Any employee who suspects money laundering or suspicious activities must     report the matter to the AML Compliance Officer immediately. The AML Compliance Officer will review and investigate the report and decide     whether it warrants a SAR filing. Pandora Rewards Inc. will cooperate fully with law enforcement and regulatory agencies as required.
‍Review and Audit The AML policy and procedures will be reviewed annually or whenever there are changes in applicable laws or regulations. Internal audits will be conducted periodically to ensure the effectiveness of the     AML program.
‍Penalties for Non-Compliance Non-compliance with this policy may result in disciplinary action, including termination of employment. In cases of regulatory violations ,legal action may be taken against the company and responsible individuals.
‍Conclusion :Pandora Rewards Inc. is dedicated to maintaining the highest standards of integrity and transparency. This AML policy is critical in safe guarding our company from being exploited for money laundering or terrorism financing purposes.