WHERE STRATEGY MEETS SUCCESS

Anti-Money Laundering Policy

1. Introduction

Squere Wealth Academy is committed to maintaining the highest standards of integrity in all business relationships and to preventing money laundering or any activity that facilitates money laundering, terrorist financing, or other financial crimes.

This Anti-Money Laundering (AML) Policy outlines our commitment to complying with all applicable AML laws and regulations in the jurisdictions where we operate, and establishes the framework for how we detect, prevent, and report suspicious activities.

2. Scope

This Policy applies to all directors, officers, employees, consultants, and contractors of Squere Wealth Academy, as well as all clients and business partners. It covers all activities, services, and transactions conducted by or on behalf of Squere Wealth Academy.

3. AML Compliance Officer

Squere Wealth Academy has designated an AML Compliance Officer who is responsible for implementing and monitoring the company's AML program. The AML Compliance Officer has the authority to ensure compliance with this Policy and relevant laws and regulations.

4. Know Your Customer (KYC) Procedures

We maintain a Know Your Customer (KYC) program to identify and verify the identity of our clients. Our KYC procedures include:

  •     Collecting and verifying client identification information
  •     Conducting risk assessments to determine the level of due diligence required
  •     Screening clients against sanctions lists and politically exposed persons (PEPs) databases
  •     Ongoing monitoring of client transactions and activities

We may request additional information or documentation from clients to complete our verification process.

5. Risk Assessment

Squere Wealth Academy conducts regular risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our services, clients, and geographic locations. Based on these assessments, we implement appropriate controls to mitigate identified risks.

6. Transaction Monitoring

We monitor client transactions to identify unusual or suspicious activities that may indicate money laundering or terrorist financing. Our monitoring includes:

  •     Reviewing transaction patterns and volumes
  •     Identifying transactions that deviate from expected behavior
  •     Investigating unusual or suspicious transactions
  •     Maintaining records of monitoring activities and investigations
7. Suspicious Activity Reporting

If we identify potentially suspicious activity, we will investigate and, if appropriate, file a Suspicious Activity Report (SAR) with the relevant authority. We will not inform the client or any third party that a SAR has been filed.

8. Record Keeping

We maintain all records related to our AML compliance program, including:

  •     Client identification and verification documents
  •     Records of client transactions
  •     Reports of suspicious activities
  •     AML training materials and records
  •     Results of AML audits and compliance reviews

These records are maintained for a minimum of five years or as required by applicable laws and regulations.

9. Employee Training

All employees of Squere Wealth Academy receive AML training appropriate to their roles and responsibilities. This training includes:

  •     Understanding AML laws and regulations
  •     Identifying red flags and suspicious activities
  •     Following AML procedures and reporting requirements
  •     Understanding the consequences of non-compliance

Training is conducted upon hiring and periodically thereafter.

10. Policy Review and Updates

This AML Policy is reviewed and updated regularly to ensure it remains effective and compliant with changing laws, regulations, and business practices. The AML Compliance Officer is responsible for overseeing these reviews and updates.

11. Consequences of Non-Compliance

Failure to comply with this AML Policy may result in disciplinary action, up to and including termination of employment or business relationship. In addition, violations of AML laws can result in significant civil and criminal penalties for both individuals and the company.

12. Contact Information

For questions or concerns regarding this AML Policy or to report suspicious activities, please contact our AML Compliance Officer at [email protected].