AML Policy
Anti-Money Laundering (AML) Policy for Solbe Technologies Limited
1. Introduction
Solbe Technologies Limited (hereinafter "Solbe", "the Company", "we", or "us") is committed to maintaining a robust anti-money laundering (AML) policy in compliance with relevant United States laws and regulations. This policy is designed to prevent the use of Solbe’s services for money laundering, terrorist financing, and other illicit financial activities. The Company engages in the trading of tokens on the Solana network, utilizing AI analytics to inform trading decisions. We are committed to ensuring that our business operations are conducted in accordance with applicable laws, including the U.S. Bank Secrecy Act (BSA), the USA PATRIOT Act, and other federal and state AML regulations.
This AML policy applies to all personnel, operations, and business activities conducted by Solbe Technologies Limited.
2. Purpose
The primary purpose of this AML policy is to:
Establish clear procedures to identify and report suspicious activities that could involve money laundering or the financing of terrorism.
Ensure Solbe complies with all relevant AML laws and regulations in the United States.
Protect the integrity and reputation of Solbe and the broader cryptocurrency ecosystem.
Provide clear guidelines for employees and stakeholders to adhere to AML standards.
3. Risk Assessment and AML Program
3.1 Risk-Based Approach
Solbe adopts a risk-based approach to anti-money laundering. This approach takes into account the nature, size, and complexity of the services provided, as well as the potential risks associated with trading tokens on the Solana network and utilizing AI analytics. Risk factors such as customer profiles, geographic location, and transaction patterns are considered when designing the Company’s AML controls.
3.2 AML Program Implementation
Our AML program is designed to identify and mitigate risks associated with money laundering and the financing of terrorism. The program includes the following key components:
Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures.
Monitoring and reporting of suspicious activities.
Record-keeping and documentation.
Training and education for employees.
Independent audit and review of AML compliance.
4. Customer Due Diligence (CDD) and Know Your Customer (KYC)
4.1 Customer Identification Program (CIP)
Solbe will not establish a business relationship or conduct transactions unless the identity of the customer is verified. We will implement the following KYC procedures:
Identity Verification: For individual customers, Solbe will obtain and verify the full name, date of birth, physical address, and government-issued identification (e.g., passport, driver’s license). For business customers, we will verify the legal name of the entity, the business address, and the names of the beneficial owners.
Verification of Risk Factors: Solbe will also assess the risk level associated with each customer, including the geographic location, the nature of their business, and the expected volume of transactions.
Ongoing Monitoring: Solbe will continuously monitor customer transactions for suspicious activities and take appropriate steps to re-verify customer information periodically.
4.2 Enhanced Due Diligence (EDD)
For customers deemed to pose a higher risk, Solbe will implement Enhanced Due Diligence (EDD) procedures. These may include:
Collecting additional information regarding the customer’s source of wealth and business activities.
Monitoring high-value transactions or transactions involving high-risk jurisdictions (e.g., countries with poor AML controls).
Conducting more frequent reviews of the customer’s account and transaction history.
5. Transaction Monitoring and Reporting
5.1 Monitoring for Suspicious Activity
Solbe employs automated systems and AI-powered analytics to monitor transactions and trading patterns in real time on the Solana network. These systems analyze customer behavior and flag any suspicious activities, including:
Transactions that are inconsistent with the customer's known business or personal profile.
Large or rapid trades that do not align with normal market activity.
Frequent use of new or anonymous wallets to move funds.
5.2 Suspicious Activity Reports (SARs)
If a transaction is deemed suspicious, Solbe will file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) in accordance with U.S. regulatory requirements. This report will be filed promptly, but no later than 30 days after the activity is identified.
The Company will also maintain all necessary records related to the suspicious activity for at least five years, as required by law.
5.3 Transaction Limits and Red Flags
Solbe will set transaction limits based on customer profiles and risk factors. Transactions exceeding predetermined thresholds will be reviewed and flagged for further scrutiny. Red flags that may trigger a review include:
Unusual trading volumes or patterns, especially from new or unverified accounts.
Transactions involving high-risk or sanctioned jurisdictions.
Activity indicating potential structuring (e.g., breaking up large transactions into smaller amounts to avoid reporting requirements).
6. Record-Keeping and Documentation
6.1 Retention of Records
Solbe will retain records of customer identification, transaction history, and any reports filed, including SARs, for at least five years from the date the transaction occurred or the report was filed. These records will be made available to regulatory authorities upon request.
6.2 Documentation of Due Diligence Efforts
Solbe will document all due diligence efforts conducted as part of the KYC process, including verification of customer identities and risk assessments. This documentation will be retained for the required period and be readily accessible for regulatory audits.
7. AML Training and Awareness
7.1 Employee Training Program
Solbe will provide mandatory AML training for all employees, particularly those involved in customer interactions and transaction monitoring. The training program will cover:
Identification of suspicious activities and red flags.
The importance of KYC and CDD procedures.
Procedures for filing SARs and handling confidential information.
Legal obligations under U.S. AML laws and regulations.
How to respond to government inquiries or investigations.
Training will be conducted annually and updated as necessary based on changes in regulations or business operations.
7.2 Compliance Officer
Solbe will appoint an experienced and qualified AML Compliance Officer (CO) responsible for overseeing the implementation and adherence to the Company’s AML policies. The CO will ensure that employees are adequately trained and that the Company remains in compliance with all applicable AML regulations.
8. Independent Audits and Reviews
8.1 Internal and External Audits
Solbe will conduct regular internal audits to assess the effectiveness of its AML policies and procedures. In addition, the Company will engage independent third-party auditors to perform annual reviews of the AML program to ensure compliance with regulations and industry best practices.
The findings from audits will be reported to senior management and any necessary improvements will be implemented promptly.
9. Compliance with U.S. and International Laws
Solbe will comply with all applicable U.S. regulations, including those enforced by FinCEN, the Office of Foreign Assets Control (OFAC), and the Securities and Exchange Commission (SEC). In addition, Solbe will adhere to international AML standards, such as those set forth by the Financial Action Task Force (FATF), where applicable.
Solbe will also monitor and comply with evolving cryptocurrency-specific regulations, ensuring that its business practices align with changes in the regulatory landscape.
10. Conclusion
Solbe Technologies Limited is committed to fighting financial crime and ensuring that all trading activities conducted on the Solana network are compliant with applicable AML laws and regulations. By implementing a comprehensive AML program, Solbe strives to prevent the use of its platform for money laundering, terrorist financing, and other illegal activities. We will continue to monitor and update our AML practices as necessary to reflect changes in regulations and to maintain the highest standards of compliance.
Approved by: Edward Reeves CEO Solbe Technologies Limited 27.02.2025
Last updated