Anti-Money Laundering (AML) Policy
KLM Quantum Holdings
Effective Date: May 23, 2025
🛡 Overview
In compliance with the Bank Secrecy Act (BSA), USA PATRIOT Act, and guidance from FinCEN, KLM Quantum Holdings adopts the following Anti-Money Laundering (AML) program to prevent, detect, and report suspicious activities.
1. Customer Identification Program (CIP)
All clients must submit:
A valid government-issued photo ID (e.g., passport or driver’s license)
Proof of address (e.g., utility bill or lease agreement)
Clients will be screened against:
OFAC’s Specially Designated Nationals (SDN) list
Global sanctions lists
2. Ongoing Monitoring & Red Flag Indicators
We actively monitor for:
Structuring deposits to avoid reporting thresholds
Unusual or inconsistent transaction patterns
Third-party funding without clear relationship
Rapid movement of funds through multiple accounts
Suspicious activity will be escalated internally and reported via a Suspicious Activity Report (SAR) if necessary.
3. Recordkeeping Requirements
We maintain:
Customer identity verification records for 5 years
SAR reports for 5 years post-filing
Transaction logs for 5 years minimum
4. Employee Training
All employees and investment agents are trained:
Upon onboarding
Annually thereafter
Training includes AML law, red flag behaviors, and reporting procedures.
5. Independent Review
An independent audit of the AML program will be conducted:
Annually
By a third-party or internal compliance officer not involved in daily operations
6. Designated AML Officer
Compliance Officer:
KLM Quantum Holding officer TBA
đź“§ compliance@klmq.xyz
This individual will oversee implementation, training, and enforcement of AML protocols.
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