AML Policy

1. Purpose of the Policy

Zabure is committed to conducting business ethically and transparently. This Anti-Money Laundering (AML) Policy is designed to prevent, detect, and report money laundering, terrorist financing, and other illegal financial activities. We recognize the importance of complying with all relevant laws, regulations, and guidelines to uphold the integrity of our business and protect our customers and stakeholders.

2. Scope of the Policy

This policy applies to all employees, contractors, agents, and any third parties working with or on behalf of Zabure. It covers all business activities, including customer interactions, financial transactions, partnerships, and any service offerings that may pose a risk of money laundering or terrorist financing.

3. Definitions

• Money Laundering: The process of concealing or disguising the origin of illegally obtained funds, typically by means of transfers involving foreign banks or legitimate businesses, to make the money appear lawful.
• Terrorist Financing: The collection or provision of funds to support terrorist activities, directly or indirectly, regardless of whether the origin of the funds is legal or illegal.
• Know Your Customer (KYC): A process to verify the identity of customers to assess and mitigate the risk of engaging with parties involved in money laundering or other illicit activities.

4. Responsibilities

• Board of Directors and Senior Management: Provide oversight and ensure the AML Policy aligns with Zabure's commitment to regulatory compliance and ethical business practices.
• AML Compliance Officer: Designated to develop, implement, and enforce the AML Policy, as well as to monitor and report any suspicious activities to the appropriate authorities.
• Employees and Contractors: Adhere to the AML Policy, attend training, and promptly report any suspicious activity or transaction to the AML Compliance Officer.

5. Customer Due Diligence (CDD)

To mitigate the risks of money laundering, Zabure has established rigorous Customer Due Diligence (CDD) procedures:

• Identification Verification: Obtain and verify identifying information for each new customer before establishing a business relationship. This includes collecting full names, valid identification documents, addresses, and contact details.
• Enhanced Due Diligence (EDD): Conduct additional scrutiny on customers deemed higher risk, including those from high-risk jurisdictions or those engaged in high-value transactions.
• Ongoing Monitoring: Regularly monitor and review customer transactions and behaviors to detect unusual or suspicious patterns.

6. Record Keeping

Zabure maintains accurate and detailed records of all transactions, customer interactions, and identification documents. Records are kept securely for a minimum period of five years, in compliance with legal and regulatory requirements. This ensures that data is readily available for inspection by regulators and investigators if necessary.

7. Reporting Suspicious Activity

Employees are required to promptly report any suspicious activities or transactions to the AML Compliance Officer, who will evaluate the information and, if necessary, file a Suspicious Activity Report (SAR) with the relevant authorities. Zabure maintains a strict policy of non-retaliation against employees who report suspicious activities in good faith.

8. AML Training Program

Zabure provides ongoing AML training to all employees to ensure they understand the risks associated with money laundering and terrorist financing, as well as their obligations under the AML Policy. Training covers topics such as identifying red flags, conducting due diligence, and the process for reporting suspicious activities.

9. Compliance Audits and Reviews

Zabure’s AML program undergoes periodic audits and reviews to assess its effectiveness and to ensure compliance with evolving laws and regulations. The AML Compliance Officer is responsible for overseeing these reviews and implementing any recommended improvements.

10. Policy Violations

Non-compliance with Zabure's AML Policy may result in disciplinary action, including termination of employment or contract, as well as potential legal consequences. Zabure takes violations seriously and is committed to maintaining the highest standards of compliance.

11. Amendments and Updates

This AML Policy is reviewed and updated regularly to align with legal requirements, regulatory changes, and best practices. Zabure remains committed to upholding the principles of transparency, integrity, and responsibility in all business activities.

12. Conclusion

Zabure’s AML Policy reflects our dedication to ethical business practices and compliance with all applicable laws. By implementing stringent measures to prevent and detect money laundering, we protect our business, customers, and stakeholders from potential risks and contribute to the fight against financial crime.