1. Purpose and Scope

This Anti-Money Laundering (AML) Policy outlines the procedures and practices that Paymato LLC ("the Company") implements to detect, prevent, and report money laundering and other financial crimes. It applies to all employees, contractors, agents, and affiliates.

2. Regulatory Compliance

Paymato LLC complies with all applicable AML laws and regulations including:

• The Bank Secrecy Act (BSA)
• USA PATRIOT Act
• FinCEN regulations
• FATF Recommendations
• [Insert other applicable laws]

3. Definitions

Money Laundering: Concealing the origins of illegally obtained money.
Terrorist Financing: Providing financial support for terrorism.
KYC (Know Your Customer): Verifying a customer’s identity and assessing their risk.

4. Risk-Based Approach

The Company uses a risk-based approach to assess and manage the AML risk posed by:

• Customers
• Geographical areas
• Products and services
• Transaction types and delivery channels

High-risk relationships are subject to enhanced due diligence (EDD).

5. Customer Due Diligence (CDD)

Before entering into a relationship, Paymato LLC will:

• Verify identity using government-issued documents
• Collect and record business and personal information
• Screen against relevant watchlists and sanctions

EDD will be conducted for high-risk clients, such as PEPs and high-volume users.

6. Monitoring and Reporting

The Company actively monitors transactions to detect suspicious behavior. In such cases:

• A Suspicious Activity Report (SAR) will be filed
• Authorities may be notified
• All related documentation will be retained securely

7. Record Keeping

Paymato LLC maintains:

• Customer records for at least 5 years
• Transaction logs and reports
• Copies of SARs and supporting materials

8. Training

All employees will receive AML training on hiring and on an annual basis, covering legal obligations, transaction monitoring, and due diligence procedures.

9. Policy Review

This policy will be reviewed annually or when regulatory changes require updates.