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1. Introduction
At Hulppy, we are committed to preventing money laundering and terrorist financing. This Anti Money Laundering (AML) Policy outlines the principles and procedures we follow to identify, assess, and mitigate money laundering risks across all our services. All employees, contractors, and partners must adhere to this policy.
2. Purpose & Scope
The purpose of this policy is to establish a robust framework that ensures compliance with applicable AML laws and regulations in all jurisdictions where we operate. It applies to all business activities, including customer onboarding, transaction monitoring, record keeping, and reporting of suspicious activities.
3. Customer Due Diligence (CDD)
We collect and verify customer identity information—such as name, date of birth, address, and government-issued ID—before establishing any business relationship. We perform risk assessments based on customer profiles, geography, and transaction patterns to categorize customers into risk tiers and apply appropriate due diligence measures.
4. Enhanced Due Diligence (EDD)
For high-risk customers or transactions—such as politically exposed persons (PEPs), unusually large transfers, or funds from high-risk jurisdictions—we conduct Enhanced Due Diligence. EDD includes obtaining additional documentation, verifying source of funds, and obtaining senior management approval prior to account activation.
5. Transaction Monitoring & Reporting
We employ automated monitoring systems and manual reviews to detect unusual or suspicious activity, including structuring, layering, or transactions inconsistent with a customer’s profile. Any suspicious transactions are immediately reported to our Compliance Officer and, where required, to the relevant Financial Intelligence Unit (FIU) in accordance with local regulations.
6. Record Keeping
We maintain comprehensive records of all identification documents, transaction histories, risk assessments, and reports for a minimum period as required by law. These records are stored securely and made available to regulators or law enforcement upon lawful request.
7. Training & Awareness
All staff receive regular AML training tailored to their roles, covering the recognition of red flags, reporting procedures, and updates on regulatory changes. We foster an organizational culture of compliance through ongoing awareness campaigns and assessments.
8. Compliance Officer
We have appointed a dedicated AML Compliance Officer responsible for overseeing the implementation of this policy, conducting periodic reviews, liaising with regulators, and ensuring timely reporting of suspicious activities.
9. Independent Audit & Review
We engage independent auditors to assess the effectiveness of our AML program at least annually. Audit findings and recommendations are reviewed by senior management and reflected in continuous improvement of our controls and procedures.
10. Policy Updates
This policy is reviewed at least once a year or whenever there are significant changes to laws or business operations. Updates are approved by senior management and communicated to all relevant stakeholders. Continued adherence to this policy is mandatory.