This Policy represents the basic standards of Anti-Money Laundering (hereinafter collectively referred to as AML) procedures of PytExchange Limited. PytExchange Limited drafted its AML policy in compliance with the Federal laws with respect to money laundering which includes but not limited to the Money Laundering Control Act 1986, Money Laundering Suppression Act 1994, Money Laundering and Financial Crimes Strategy Act 2002 and Intelligence Reform and Terrorism Prevention Act 2004.
PytExchange LLC ("PytExchange LLC") has adopted an Anti-Money Laundering (AML) compliance policy ("Policy"). For avoidance of doubt and the purposes of this agreement and policy, any statement in the text below referring to PYTEXCHANGE is also referring to PytExchange LLC as the owner of this site and any reference made to PytExchange LLC.
It is the policy of PytExchange LLC to prevent and actively and tirelessly pursue the prevention of money laundering and any activity that facilitates money laundering as well as staying in line with the Combating the Financing of Terrorism (CFT). PytExchange LLC is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes. This policy is thus in effect and copies of this Policy will be distributed to all and all relevant employees must be thoroughly familiar with and make use of the material contained in this Policy.
Money laundering is a generic term used to describe any process that conceals the origin or derivation of the proceeds of crime so that the proceeds appear to be derived from a legitimate source. Money laundering is sometimes wrongly regarded as an activity that is associated only with organized crime and drug trafficking. It is not. It occurs whenever any person deals with another person’s direct or indirect benefit from crime. The term ‘money laundering’ is in fact a misnomer. Often it is not money that is being laundered but other forms of property that directly or indirectly represent benefit from crime. Any form of tangible or intangible property is capable of representing another person’s benefit from crime. The main objective of the money launderer is to transform ‘dirty’ money into seemingly clean money or other assets in a way to leave as little trace as possible of the transformation. Traditionally, money laundering has been described as a process that takes place in three stages as follows:Placement – This is the first stage in which illicit funds are separated from their illegal source. Placement involves the initial injection of the illegal funds into the financial system or carrying of cash across borders. Layering – After successfully injecting the illicit funds into the financial system, laundering them requires creating multiple layers of transactions that further separate the funds from their illegal source. The purpose of this stage is to make it more difficult to trace these funds to the illegal source. Integration – This is the final stage in a complete money laundering operation. It involves reintroducing the illegal funds into the legitimate economy. The funds now appear as clean income. The purpose of the integration of the funds is to allow the criminal to use the funds without raising suspicion that might trigger investigation and pursuit. In reality, the three stages often overlap and the benefit from many crimes including most financial crimes does not need to be ‘placed’ into the financial system. Money laundering is a crime that is most often associated with banking and money remittance services. Whilst banks are often an essential part of successful laundering schemes, the financial and related services that Licensees offer are also vulnerable to abuse by money launderers.
An individual employee shall be appointed as Chief Compliance Officer which will oversee PytExchange LLC’s AML program and be responsible for arranging audits. The designated AML Officer will head the AML Committee which will be made up of the Corporate Attorney and the company shareholders. With respect to the Policy, the AML Compliance Committee’s duties include, but are not limited to, the implementation of and updating the Policy as required; dissemination of information to officers, employees and appointed producers of PYTEXCHANGE LLC, training of officers, employees and appointed producers; monitoring the compliance of PYTEXCHANGE LLC operating units and appointed producers, while maintaining necessary and appropriate records, filing of Suspicious Activity Reports (SARs) when the need arises; as well as independent assessment of the suitability and enforceability of the Policy.