QUIBO FINTECH LLC
Anti-Money Laundering (AML) Policy

1. Introduction

This Anti-Money Laundering (AML) Policy is established by QUIBO FINTECH LLC, a Money Services Business (MSB) registered in the Florida Office of Financial Regulation (FLOFR).

This policy outlines the procedures QUIBO FINTECH LLC will implement to comply with the Bank Secrecy Act (BSA) and Florida AML regulations to prevent and detect money laundering and terrorist financing activities.

2. Regulatory Requirements

This policy acknowledges the following key regulations:

  • The Bank Secrecy Act (BSA)
  • 31 C.F.R. s. 1022.210 (Establishing a written Anti-Money Laundering Program)
  • 31 C.F.R. Part 10 (Customer Identification Program (CIP) Rule)
  • 31 C.F.F.R. Part 103 (Customer Due Diligence (CDD) for Financial Institutions)
  • Florida Statutes Chapter 560 (Florida Money Transmitters Act)

3. Customer Identification Program (CIP)

QUIBO FINTECH LLC will implement a Customer Identification Program (CIP) to verify the identity of all bolivian customers, this includes:

  • Obtaining a bolivian government-issued photo ID or Passport for each customer.
  • Recording customer information, including name, address, date of birth, and ID or Passport number.
  • Verifying the accuracy of customer information.

4. Customer Due Diligence (CDD)

QUIBO FINTECH LLC will conduct Customer Due Diligence (CDD) on all customers based on risk assessment, this may include:

  • Simplified Measures: For low-risk customers, we will obtain basic information and verify identity documents.
  • Enhanced Measures: For higher-risk customers, we will obtain additional information, such as the source of funds, nature and purpose of business relationships, and beneficial ownership structure.

5. Transaction Monitoring

QUIBO FINTECH LLC will monitor customer transactions for suspicious activity, this includes:

  • Monitoring for transactions exceeding thresholds established by regulations or internal risk assessments.
  • Identifying transactions that are inconsistent with a customer’s profile or business activity.
  • Reporting suspicious activity to the Financial Crimes Enforcement Network (FinCEN).

6. Record Keeping

QUIBO FINTECH LLC will maintain records of customer identification information, transaction data and any Suspicious Activity Reports (SARs) filed. Records will be retained for the period required by regulations for at least five years.

7. Training

QUIBO FINTECH LLC will provide ongoing AML training to all employees to ensure they understand the AML regulations, identification procedures, and suspicious activity indicators.

8. Risk Assessment

QUIBO FINTECH LLC will conduct periodic risk assessments to identify and mitigate potential money laundering and terrorist financing risks associated with our customer base and services.

9. Reporting

QUIBO FINTECH LLC will report suspicious activity to FinCEN by filing when detected Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs)

10. Independent Review

QUIBO FINTECH LLC will conduct periodic independent reviews of its AML program to ensure its effectiveness and compliance with regulations.

11. Program Updates

This AML policy will be reviewed and updated periodically to reflect changes in regulations, industry best practices, and the risk profile of the business.