Anti-Money Laundering Policy

Proficient Path is committed to preventing money laundering and financing of terrorism in all of our business operations. This Anti-Money Laundering (AML) Policy outlines our procedures and measures to detect, prevent, and report any suspicious activities in compliance with relevant laws and regulations.

1. Purpose

The purpose of this AML Policy is to ensure that Proficient Path conducts business in a safe, ethical, and compliant manner. We are dedicated to adhering to all relevant anti-money laundering regulations, and we expect our employees, partners, and customers to share this commitment.

2. Scope

This policy applies to all employees, contractors, and third-party associates of Proficient Path. It governs all activities, including, but not limited to, customer onboarding, monitoring transactions, and reporting suspicious activities.

3. Customer Due Diligence (CDD)

To comply with AML regulations, Proficient Path conducts Customer Due Diligence (CDD) to verify the identity of our customers and assess the potential risk of illegal activities. This includes:

  • Identification Verification: Collecting information such as name, address, date of birth, and other identifying documents.

  • Risk Assessment: Evaluating each customer’s risk based on their background, business activities, and transaction patterns.

  • Enhanced Due Diligence (EDD): For customers identified as high-risk, Proficient Path may request additional documentation and conduct more thorough checks.

4. Record Keeping

Proficient Path maintains comprehensive records of all customer information, transaction history, and any actions taken in response to suspicious activities. We are committed to retaining these records for a minimum period as required by applicable regulations.

  • Transaction Records: All financial transactions are recorded and monitored to detect unusual patterns.

  • Customer Information: Customer data is securely stored and protected, with access limited to authorized personnel only.

5. Monitoring and Reporting Suspicious Activity

Proficient Path actively monitors transactions for any signs of suspicious or unusual activity that may indicate money laundering or terrorism financing. In the event of identifying such activities, we are committed to reporting them to the relevant authorities.

  • Transaction Monitoring: Regularly monitoring transactions to identify anomalies.

  • Suspicious Activity Reports (SARs): If suspicious activity is detected, Proficient Path will submit a Suspicious Activity Report to the appropriate regulatory authority as required by law.

6. Employee Training

Proficient Path provides regular training to all employees on AML practices, including identifying and reporting suspicious activities. Our training programs are designed to ensure that employees understand the importance of AML compliance and can recognize red flags.

  • Mandatory Training: All new employees undergo AML training as part of their onboarding process.

  • Ongoing Training: Refresher courses and updates are provided to keep employees informed of regulatory changes and best practices.

7. Roles and Responsibilities

The responsibility for AML compliance is shared across all levels of the organization:

  • Compliance Officer: A designated Compliance Officer oversees AML efforts, ensuring policies are followed and reporting is conducted in line with regulatory requirements.

  • Employees: Every employee is responsible for identifying potential risks and reporting suspicious activities to the Compliance Officer.

8. Non-Compliance and Disciplinary Action

Failure to comply with AML policies and regulations may lead to disciplinary actions, including termination of employment. Proficient Path reserves the right to take necessary actions against any employee, partner, or customer involved in suspicious or non-compliant behavior.

9. Policy Review and Updates

This AML Policy will be reviewed and updated regularly to ensure compliance with any changes in regulatory requirements or industry standards.

10. Contact Information

For any questions or concerns related to this AML Policy, please contact:

Email: [email protected]
Address: 3 Kakal Givatyiim, Israel