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
📧 compliance@klmq.xyz

This individual will oversee implementation, training, and enforcement of AML protocols.