n2xo
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AML Policy

Last updated: March 2026

ANTI-MONEY LAUNDERING (AML) AND COUNTER-TERRORIST FINANCING (CTF) POLICY

INTRODUCTION

This Anti-Money Laundering and Counter-Terrorist Financing Policy ("AML Policy") outlines the framework implemented by N2XO INC ("Company"), a Money Services Business (MSB) registered in the United States, to prevent money laundering, terrorist financing, fraud, and other financial crimes.

The Company complies with applicable U.S. regulations, including:

  • Bank Secrecy Act (BSA)
  • USA PATRIOT Act
  • FinCEN regulations
  • Office of Foreign Assets Control (OFAC)

SCOPE

This Policy applies to:

  • All employees and contractors
  • All customers
  • All transactions

AML GOVERNANCE

The Company appoints an AML Compliance Officer responsible for:

  • AML program implementation
  • Filing Suspicious Activity Reports (SARs)
  • Regulatory communication

The Company maintains internal controls and conducts periodic reviews.

Employees receive AML training at least annually.

CUSTOMER DUE DILIGENCE

We perform KYC/KYB by verifying:

  • Identity and corporate structure
  • Beneficial owners
  • Source of funds

Enhanced Due Diligence (EDD) applies to:

  • High-risk jurisdictions
  • Politically Exposed Persons (PEPs)
  • Suspicious activity

Customer activity is continuously monitored.

SANCTIONS COMPLIANCE

We screen all customers and transactions against OFAC and global sanctions lists.

We do not provide services to sanctioned parties.

TRANSACTION MONITORING

We monitor for:

  • Unusual behavior
  • Structuring
  • Rapid fund movement
  • High-risk locations

SUSPICIOUS ACTIVITY REPORTING

We report suspicious activity to FinCEN where required.

RECORDKEEPING

We retain:

  • Customer data
  • Transaction records

Minimum retention period: 5 years.

RISK ASSESSMENT

We assess:

  • Customer risk
  • Geographic risk
  • Product risk
  • Transaction risk

PROHIBITED USE

Users may not:

  • Use services for illegal purposes
  • Evade sanctions
  • Finance terrorism

DATA PROTECTION

All data is protected using appropriate security measures.

WHISTLEBLOWING

Employees may report concerns confidentially.

POLICY UPDATES

This Policy may be updated periodically.

CONTACT

office@n2xo.com