AML/CTF & KYC program
STATESPAY TECHNOLOGIES LLC
Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Program
Effective Date: 04/05/2025
Approved by: Statespay Technologies LLC / CEO
1. Program Overview
StatesPay maintains a risk-based AML/CTF program to:
- Comply with the Bank Secrecy Act (BSA), USA PATRIOT Act, and FinCEN regulations.
- Detect and report suspicious activity, including money laundering and terrorist financing.
- Partner with FDIC-insured institutions (Bluebanc, Sila Money) to ensure secure transactions.
Scope: Covers all customer accounts, P2P transfers, virtual cards, and fund loading services.
2. AML Compliance Officer
Name: [Designated Officer Name]
Responsibilities:
- Oversee AML program implementation.
- File SARs/CTRs via FinCEN’s BSA E-Filing System.
- Conduct annual employee training.
- Update policies per regulatory changes.
3. Customer Identification Program (CIP)
Verification via Plaid:
- Collect for all customers: Name, DOB, address, SSN/ITIN, government-issued ID.
- Enhanced Due Diligence (EDD): Applied to high-risk accounts (e.g., transactions >$10,000, PEPs).
- Record Retention: 5 years post-account closure.
Prohibited Customers:
- Foreign shell banks.
- Entities on OFAC’s SDN list or high-risk jurisdictions (e.g., FATF blacklisted).
4. Suspicious Activity Monitoring
Red Flags:
- Transactions inconsistent with customer profile.
- Structuring to avoid reporting thresholds.
- High-volume transfers to/from high-risk countries.
Reporting:
- File SARs within 30 days of detection (or 60 days if suspect unidentified).
- Emergency reporting: Immediate notice to FinCEN/FBI for terrorist financing.
5. Transaction Reporting
Report Type | Threshold | Filing Deadline |
| SAR (Suspicious Activity) | $5,000+ or red flags | 30 days |
| CTR (Currency) | $10,000+ in cash | 15 days |
| FBAR (Foreign Accounts) | Aggregate $10,000+ | April 15 annually |
6. Employee Training
- Annual training on:
- Red flag detection.
- SAR/CTR filing procedures.
- Penalties for non-compliance.
- Specialized training for compliance/operations staff.
7. Independent Testing
- Annual audit by Statespay Technologies LLC.
- Focus areas: CIP adherence, SAR filings, EDD processes.
- Findings reported to senior management with corrective actions.
8. Recordkeeping
- Retain SARs, CIP documents, and transaction records for 5 years.
- Secure storage with restricted access (encrypted digital/cloud-based).
9. Penalties for Non-Compliance
- Civil: Up to $250,000 per violation.
- Criminal: Fines up to $500,000 and/or 10 years imprisonment.
Approval
This policy is approved by:
Satespay Technologies LLC / CEO
