Anti-Money Laundering Policy

INTRODUCTION AND PURPOSE 

The purpose of this policy is to set forth DerbySoft, Inc. and its subsidiaries and affiliated companies (collectively, the “Company”) commitment to detect suspicious or illicit activities, and the procedures the Company undertakes to prevent and control such activities by the means defined in this policy.  There are set guidelines and procedures in this policy adopted by the Company to detect and prevent money laundering activities by complying with the applicable regulations. This policy ensures that the Company is complying with all the applicable laws and regulations and protecting itself from being used as a channel for any illegal activities.

DEFINITIONS AND SCOPE

This policy applies to all employees, officers, and affiliates of the Company. The purpose of this policy is to establish an effective framework for the detection and prevention of money laundering activities.

The following terms are defined with reference to this policy:

Money Laundering: Money laundering is the process of hiding the original illegal source of money and converting it to a legal source. This helps criminals to use these assets without endangering their source.

Terrorist Financing: Terrorist financing refers to the act of supporting and providing resources to individuals or groups involved in terrorist activities.

Politically Exposed Persons (PEPs): A politically exposed person is one who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence they may hold.

REGULATORY FRAMEWORK

DerbySoft follows the regulatory framework of FinCEN (Financial Crimes Enforcement Network) and local laws and regulations regarding anti-money laundering regulations and procedures, and is also mindful of regulations issued by the Bank Secrecy Act (BSA), the USA Patriot Act, and other applicable federal and state laws.

COMPLIANCE PROCEDURES

The Company follows the following procedures to ensure that compliance with all anti-money laundering regulations is done in a corrective manner:

Defined Roles: DerbySoft ensures the effective implementation of the AML policy by ensuring that all employees are aware of and are regularly updated on the same. Regular training is provided to employees so that they can report in a corrective manner if any suspicious activity is detected.

Internal Control and Policies: DerbySoft will create associated policies and internal tools from time to time, by which they regulate the anti-money laundering framework. 

Reporting: DerbySoft regularly monitors its financial transactions and reports any suspicious activity as soon as it is detected. Employees or related parties are encouraged to report instances of anti-money laundering violations if they find anything suspicious.

KNOW YOUR CUSTOMER AND DUE DILLIGENCE

Know Your Customer (KYC) and Customer Due Diligence (CDD) are important tools in reference to this policy. This helps in identifying customers and understanding their business activities, which would further help in analyzing whether they fall under the suspicious category or not.

The following factors are included for complying with KYC and CDD:

• Verification of ID (Identification Document) of Customers; 
• Verification of the identity of the Ultimate beneficial Owners (UBOs) in case of entities;
• PEP screening to know if any of the individuals or companies is or are related to any PEP; and
• Understanding the nature or business and the products offered by the individual or entity.

POLICY UPDATES

The AML policy will be reviewed periodically and shall be updated from time to time when required, and the changes shall be communicated to the relevant personnel accordingly.