Effective Date: 4/9/2025
Approved By: ReelGrowth Compliance Committee
Review Cycle: Annually
1. Purpose
The purpose of this Anti-Money Laundering (AML) Policy is to outline the framework and procedures established by ReelGrowth to prevent, detect, and report any activity that may involve money laundering, terrorist financing, or other illicit financial behavior. This policy reflects ReelGrowth’s commitment to compliance with all applicable AML laws, including but not limited to:
- The USA PATRIOT Act
- The Bank Secrecy Act (BSA)
- The Financial Action Task Force (FATF) Recommendations
- Applicable local, national, and international AML regulations
2. Scope
This policy applies to all:
- Employees, officers, contractors, and affiliates of ReelGrowth
- Users of the ReelGrowth platform, including both lead sellers and lead purchasers
- Transactions, data, and processes managed or facilitated by the ReelGrowth platform
3. Definitions
- Money Laundering: The process of concealing the origins of illegally obtained money through a series of legitimate financial transactions.
- Terrorist Financing: The act of providing financial support to individuals or groups that engage in terrorism.
- KYC (Know Your Customer): Procedures for verifying the identity of customers and assessing risk.
- EDD (Enhanced Due Diligence): Additional measures required for high-risk customers or transactions.
4. Governance and Responsibility
ReelGrowth has appointed a dedicated AML Compliance Officer who is responsible for:
- Developing and enforcing AML policies and procedures
- Coordinating AML training for staff
- Monitoring compliance with legal obligations
- Reporting suspicious activities to the relevant Financial Intelligence Unit (FIU) or regulator
- Acting as the point of contact for law enforcement and regulators
5. Customer Due Diligence (CDD)
ReelGrowth performs Customer Due Diligence for all platform participants. This includes:
a. Identification and Verification
- Collection of full name, address, government-issued identification, business registration documents (for legal entities), and other identifying data
- Verification against reliable, independent sources (e.g., government databases)
b. Risk Profiling
- Customers are assigned a risk level based on their profile, location, transaction behavior, and industry sector
- High-risk customers undergo Enhanced Due Diligence (EDD), including more frequent monitoring and source of funds checks
c. Politically Exposed Persons (PEPs)
- PEPs and their associates are subject to additional scrutiny and senior management approval before onboarding
6. Ongoing Monitoring and Controls
ReelGrowth applies a risk-based approach to monitor and review customer activity. This includes:
- Automated monitoring tools to flag unusual patterns or large-volume transactions
- Periodic reviews of customer profiles and behavior
- Transaction monitoring rules that adapt over time based on emerging typologies
7. Suspicious Activity Reporting (SAR)
ReelGrowth is committed to reporting all suspicious activities to the appropriate authorities in accordance with the law. Employees are trained to identify red flags and escalate them to the Compliance Officer, who will determine whether to file a Suspicious Activity Report (SAR).
8. Recordkeeping
ReelGrowth maintains accurate records of:
- KYC documentation
- Transaction logs
- SARs and internal reports
- Risk assessments and internal audit findings
All records are retained for a minimum of five (5) years from the end of the business relationship or the date of the transaction, whichever is later.
9. Training and Awareness
All employees and contractors of ReelGrowth receive AML training upon onboarding and annually thereafter. The training includes:
- AML laws and regulations
- Company procedures and red flags
- Reporting obligations and escalation processes
Training completion is tracked and enforced as a compliance requirement.
10. Independent Audit
An independent review of the AML program is conducted annually to:
- Evaluate the effectiveness of controls
- Ensure adherence to laws and regulations
- Recommend areas for improvement
Findings are reviewed by senior management and the Compliance Committee.
11. Sanctions and Prohibited Activities
ReelGrowth does not conduct business with:
- Individuals or entities listed on sanctions lists (e.g., OFAC, EU Sanctions, UN Sanctions)
- Shell banks or anonymous accounts
- Businesses operating in high-risk jurisdictions without appropriate due diligence
All customers are screened against global sanctions lists before onboarding and on a recurring basis.
12. Policy Review
This AML Policy is reviewed at least once per year or upon any material change in business operations or regulatory requirements. All revisions must be approved by the AML Compliance Officer and senior management.
Contact Information
To report a suspicious activity or ask AML-related questions, contact:
📧 [email protected]