AML Policy

Anti-Money Laundering and Anti-Terrorism Policy

1.Anti-Money Laundering and Anti-Terrorism Policy

It is the policy of YUSD Global Exchange and AI Income to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, ponzi schemes, cybercrime and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

Rules: 31 C.F.R. § 1023.210; FINRA Rule 3310.

2. AML Compliance Person Designation and Duties

Designate your firm’s AML Compliance Person and describe his or her duties.

The firm has designated Perry Jones, CEO, as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. Mr. Jones has a working knowledge of the BSA and its implementing regulations and is qualified by experience, knowledge and training, including serving several years as a registered and licensed financial advisor and mutual funds sales representative. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees, and [add any other duties your firm will assign to the AML Compliance Person; review NASD Rules 1021 and 10311 for any applicable registration requirements]. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SARs) are filed with the Financial Crimes Enforcement Network (FinCEN) when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.

The firm will provide FINRA with contact information for the AML Compliance Person through the FINRA Contact System (FCS), including: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile (if any). The firm will promptly notify FINRA of any change in this information through FCS and will review, and if necessary update, this information within 17 business days after the end of each calendar year. The annual review of FCS information will be conducted by [Name] and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, [Name] will update the information promptly, but in any event not later than 30 days following the change.

Rules: 31 C.F.R. § 1023.210; FINRA Rule 3310; FINRA Rule 4517. Resources: Regulatory Notice 07-42; NTM 06-07; NTM 02-78. Firms can submit their AML Compliance Person information through FINRA's FCS web page.

3.Active Investigation

YUSD Global Exchange and AI Income associate each account holder with an IP address. In the event of unusual or suspicious activity regarding a user's account, YUSD Global Exchange and or AI Income will contact authorities local to the suspect IP address and register a "suspicious activity" notice with INTERPOL.

YUSD Global Exchange and AI Income are vigilant in prohibiting money laundering, terrorist financing or other illegal and terrorist activity relative to this website. In addition to informing INTERPOL and local authorities, YUSD Global Exchange may send a "ground team" to the location of the IP address and conduct an investigation of the suspected activity. YUSD Global Exchange investigative team members are all certified investigators and also are all former members of various military, investigative or law enforcement agencies. Our investigative activity at the locale may include the confiscation of all property at the scene which is then turned over to INTERPOL authorities.

For further information, contact us at