QUIBO FINTECH LLC / BSA POLICIES

1. Introduction and Purpose

1.1 Overview

This document outlines the policies and procedures for compliance with the Bank Secrecy Act (BSA) for QUIBO FINTECH LLC, a Money Service Business (MSB – Money Transmitter) whose unique target market (niche) are bolivian residents and non-residents in the State of Florida.

Therefore, our money services will only be available for bolivian residents and non-residents in the State of Florida.

The primary objective of these policies are that QUIBO FINTECH LLC’s doing business in the State of Florida prevents and detects money laundering and other financial crimes.

1.2 Purpose

The purpose of these policies is to ensure compliance with federal and state regulations, to establish a robust anti-money laundering (AML) program, and to protect QUIBO FINTECH LLC from risks associated with illicit activities.

2. BSA Compliance Program

2.1 Appointment of a BSA Compliance Officer

  • Designation:
    Alejandro IMANA ARGANDONA, CEO/SUP, is designated as the BSA Compliance Officer at FinCEN and the Florida Office of Financial Regulation (FLOFR).
  • Responsibilities:
    Overseeing the implementation and maintenance of the BSA/AML program, ensuring staff training, and serving as the point of contact for regulatory agencies.

2.2 Development of Internal Policies, Procedures, and Controls

  • Establish detailed AML policies tailored to the company’s specific risk profile.
  • Ensure procedures cover customer identification, recordkeeping, reporting suspicious activities, and conducting independent audits.

3. Customer Identification Program (CIP)

3.1 Customer Due Diligence (CDD)

  • Identification Requirements:
    QUIBO FINTECH LLC will collect and verify the following for all bolivian customers:
    • Full name
    • Date of birth
    • Physical address (P.O. boxes are not acceptable)
    • Identification number (Bolivian Passport, Bolivian CI or US Driver Licence)
  • Enhanced Due Diligence (EDD):
    QUIBO FINTECH LLC will apply additional scrutiny to higher-risk customers, such as bolivian non-resident aliens, politically exposed persons (PEPs), and those with complex ownership structures.

3.2 Recordkeeping

  • QUIBO FINTECH LLC will maintain records of customer identification for at least five years after the account is closed.
  • QUIBO FINTECH LLC wil keep transaction records for at least five years following the transaction date.

4. Transaction Monitoring and Reporting

4.1 Monitoring Transactions

  • QUIBO FINTECH LLC will implement in QUIBO APP the following rules:
    a.- USD 500 daily amount transaction for a single user.
    b.- Two transactions per user per day, wich sums in total no more than USD 500.
    c.- A cumulative of no more than USD 5,000 in transactions per month.
  • QUIBO FINTECH LLC will set thresholds for suspicius transactions that trigger further review.

4.2 Suspicious Activity Reports (SARs)

  • Criteria for Filing:
    QUIBO FINTECH LLC will file a SAR for any transaction or series of transactions that appear suspicious or indicative of money laundering.
  • Filing Deadline:
    QUIBO FINTECH LLC will submit SARs within 30 days of detecting suspicious activity.
  • Confidentiality:
    QUIBO FINTECH LLC ensures that SAR filings are confidential and not disclosed to the subject of the report.

4.3 Currency Transaction Reports (CTRs)

  • Criteria for Filing:
    QUIBO FINTECH LLC is commited to file a CTR for any cash transaction exceeding USD 10,000.
  • Filing Deadline:
    QUIBO FINTECH LLC will submit CTRs within 15 days of the transaction.

5. Compliance with State Regulations

5.1 Florida-Specific Requirements

  • QUIBO FINTECH LLC is registered with the Florida Office of Financial Regulation (FLOFR) and will maintain current licensure for all the time our money service business are offered to bolivian residents and non-residents in the State of Florida.
  • QUIBO FINTECH LLC will adhere to state-specific reporting requirements, including state-specific thresholds and additional forms as required.

6. Employee Training

6.1 Training Program

  • Frequency:
    QUIBO FINTECH LLC will conduct training sessions at least annually.
  • Content:
    QUIBO FINTECH LLC will cover BSA/AML regulatory requirements, internal policies and procedures, detection of suspicious activity, and proper reporting channels.
  • Recordkeeping:
    QUIBO FINTECH LLC will maintain training records, including attendance and content, for at least five years.

7. Independent Review and Audit

7.1 Independent Testing

QUIBO FINTECH LLC will conduct independent audits of the BSA/AML program at least annually.

  • Scope:
    QUIBO FINTECH LLC will ensure the audit covers compliance with federal and state regulations, effectiveness of the AML program, and adherence to internal policies.
  • Report and Follow-Up:
    QUIBO FINTECH LLC will document audit findings, report them to senior management, and ensure corrective actions are implemented.

8. Record Retention

8.1 Retention Periods

  • Customer Identification Records:
    QUIBO FINTECH LLC will retain for five years after account closure.
  • Transaction Records:
    QUIBO FINTECH LLC will retain for five years following the transaction date.
  • SAR and CTR Records:
    QUIBO FINTECH LLC will retain copies for five years from the date of filing.

9. Reporting to Regulatory Authorities

9.1 Communication

  • Regulatory Reporting:
    QUIBO FINTECH LLC ensures timely and accurate reportings to FinCEN, OFR, and other relevant authorities.
  • Point of Contact:
    QUIBO FINTECH LLC BSA compliance officer will act as the liaison for all communications with regulatory bodies.

10. Review and Update of Policies

10.1 Regular Review

QUIBO FINTECH LLC will review and update BSA/AML policies and procedures annually or more frequently if needed due to changes in regulations or business operations.

By following these policies and procedures, QUIBO FINTECH LLC will maintain compliance with the BSA, reduce risks associated with money laundering, and ensure the integrity of its operations in the State of Florida.