1. Overview
[PLACEHOLDER] Boro Marble League LLC (“Company”) is committed to complying with all applicable anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) laws and regulations, including [ATTORNEY TO SPECIFY APPLICABLE LAWS — Bank Secrecy Act, FinCEN guidance, state-specific requirements, etc.].
[PLACEHOLDER] This policy establishes our procedures for knowing our customers (“KYC”), monitoring transactions, and reporting suspicious activity. All employees and contractors are required to comply with this policy.
2. Customer Due Diligence
[PLACEHOLDER] The Company applies a risk-based approach to customer due diligence:
- Standard CDD: Applied to all new customers at registration. Includes age verification and state of residence confirmation.
- Enhanced Due Diligence (EDD): Applied to customers who exceed prize redemption thresholds of [ATTORNEY TO SET THRESHOLD], or who exhibit indicators of higher risk.
- Simplified CDD: May apply to lower-risk accounts as determined by our risk assessment framework.
3. Identity Verification
[PLACEHOLDER] Before processing prize redemptions above $[THRESHOLD — ATTORNEY TO CONFIRM], the Company requires verification of the following:
- Full legal name;
- Date of birth (must be 18+);
- Residential address (no P.O. boxes);
- Government-issued photo ID (passport, driver's licence, or national ID card);
- Tax identification number (SSN or ITIN for US residents).
[PLACEHOLDER] Identity verification is conducted through [VENDOR TO BE SELECTED — e.g., Persona, Jumio, Onfido, or manual review]. The Company reserves the right to request additional documentation at any time.
4. Transaction Monitoring
[PLACEHOLDER] The Company monitors all redemption activity for indicators of suspicious behaviour, including:
- Structured transactions designed to avoid reporting thresholds;
- Unusually large or frequent redemptions inconsistent with account history;
- Multiple accounts linked to the same individual or household;
- Redemption requests to high-risk jurisdictions;
- Use of VPN, proxy, or anonymisation services.
5. PEP & Sanctions Screening
[PLACEHOLDER] All accounts are screened against:
- OFAC Specially Designated Nationals (SDN) list;
- Politically Exposed Persons (PEP) databases;
- Other applicable government sanctions lists.
[PLACEHOLDER] Accounts matching sanctions lists will be immediately frozen and reported to the appropriate authorities. PEP accounts are subject to enhanced due diligence.
6. Suspicious Activity Reporting
[PLACEHOLDER — ATTORNEY TO CONFIRM SAR OBLIGATIONS] Where the Company identifies or has reason to suspect that a transaction or customer may be connected with money laundering or terrorist financing, the Company will file a Suspicious Activity Report (SAR) with FinCEN as required by applicable law. The Company will not “tip off” the subject of a SAR.
7. Record Keeping
[PLACEHOLDER — ATTORNEY TO CONFIRM RETENTION PERIODS] The Company retains records of all identity verification documents, transaction records, and SAR filings for a minimum of [X years] from the date of account closure or last transaction, as required by applicable law.
8. Staff Training
[PLACEHOLDER] All employees with access to customer data or transaction processing receive AML/KYC training upon onboarding and annually thereafter. Training covers recognition of suspicious activity, reporting obligations, and the prohibition on tipping off.
9. Enforcement & Consequences
[PLACEHOLDER] Violation of this policy by employees may result in disciplinary action up to and including termination and referral to law enforcement. Customers found to be in violation of AML/KYC requirements will have their accounts frozen and relevant authorities notified as required by law.
10. Contact
[PLACEHOLDER] AML/KYC compliance inquiries should be directed to our Compliance Officer:
compliance@boromarbleleague.com
Boro Marble League LLC
[ADDRESS — ATTORNEY TO CONFIRM]