AML Program

Introduction & Risk Assessment

Our AML program is designed to prevent Poolit from being used for money laundering or the financing of terrorist activities. We adhere to the AML Statutory Standards and have a dedicated team responsible for the AML program. We also conduct annual AML training and regular testing and monitoring of our AML program compliance.

Risk-Based Program

We have a risk-based AML program that is tailored to the specific risks associated with our firm. We have developed aggressive procedures to address these risks, taking into account factors such as the nature of our investment offerings, our multinational investor base, and the frequency and type of transactions we enter into.

Customer Identification & Prohibited Relationships

We have a robust Customer Identification Program (CIP) that meets the standards set by the Patriot Act. We only accept subscriptions from reputable investors whose identities have been verified. We do not do business with individuals or entities with questionable integrity or financial conduct, or those who have been convicted of money laundering or a related financial crime.

Identification of Individuals and Institutions/Entities

We require specific data for individual and institutional/entity investors. This includes name, residence address, date of birth, country of residence, country of citizenship, and more. For institutions/entities, we require additional information such as the entity's full legal name, address, date of incorporation, type of entity, and more.

Non-Documentary Verification

We supplement our identification documents with non-documentary verification. This includes contacting the investor after the relationship has been established, comparing investor information against third-party verification services, and obtaining references from reliable sources.

Beneficial Ownership Determination

We obtain and verify information for persons who own entities that are not domestic US public corporations. This applies to corporate shareholders, partners, beneficial owners, directors, grantors, and other entity principals/owners with greater than 25% ownership in the entity.

AML Sensitivity Ratings

We assess all our investors to determine their AML Sensitivity Rating. This rating is based on three tiers – Prohibited, High Risk, and Low Risk. We regularly update these ratings based on the investor's circumstances.

Politically Exposed Persons (PEPs)

We have a detailed definition of PEPs and require additional KYC requirements for high-risk investors. This includes obtaining additional information such as country of birth, background check, occupation, current employer name and address, current income, net worth, and source of wealth.

Suspicious Activity & Other Red Flags

We have procedures in place to detect and report suspicious transactions. We monitor account activity for unusual size, volume, pattern, or type of transactions. We also identify "red flags" or indicators of possible suspicious activity that warrant further due diligence.

Please note that this is a high-level overview and does not cover all the details of our AML policy. For a complete understanding, please refer to our full Anti-Money Laundering & Customer Identification Policy.