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Anti-Money Laundering (AML) Policy for Stable Payments

1. Introduction

Stable Payments is committed to the highest standards of anti-money laundering (AML) compliance and to preventing its services from being used for the purposes of money laundering, terrorist financing, or any other financial crimes. This policy outlines the framework and procedures we have established to ensure compliance with the laws and regulations of the United States and Saint Kitts and Nevis, as well as adherence to international best practices.

2. Company Overview

• Core Services: Stable Payments specializes in providing a secure and user-friendly cryptocurrency wallet application, primarily focused on USDT transactions within the Polygon network. Our services facilitate seamless transfers of USDT between users.
• API Integration: We offer robust API solutions for third-party applications, extending our wallet functionalities to a broader ecosystem.
• Partnership with Transak: For fiat-to-crypto conversions, we have partnered with Transak, leveraging their comprehensive KYC and AML compliance procedures to ensure secure and compliant user onboarding.

3. Legal and Regulatory Framework

United States Compliance:

• FinCEN Registration: As part of our commitment to compliance, we are registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB), adhering to the stringent requirements set forth by the Bank Secrecy Act (BSA).
• KYC and CIP: We implement rigorous Customer Identification Programs (CIP) and Know Your Customer (KYC) procedures, in line with U.S. standards, to verify the identities of our users, particularly during the onboarding process facilitated by our partner, Transak.
• SAR and Record-keeping: Our policies ensure diligent monitoring, documentation, and reporting of any suspicious activities, with strict adherence to SAR filing requirements and record-keeping obligations as per BSA guidelines.

Saint Kitts and Nevis Compliance:

• Regulatory Adherence: We comply with the local financial services and AML regulations as overseen by the Financial Services Regulatory Commission, ensuring our operations meet the legal standards set by Saint Kitts and Nevis authorities.
• International Standards: Stable Payments aligns its operations with the FATF recommendations, demonstrating our commitment to global AML and CFT (Combating the Financing of Terrorism) standards.

4. Risk Assessment

• AMLBot Integration: We utilize AMLBot, a leading AML compliance tool, to conduct real-time risk assessments of all wallets and users upon registration. AMLBot's advanced algorithms help us identify and mitigate potential risks associated with illicit financial activities.
• Risk Categorization: Based on AMLBot's analysis, we categorize users and wallets into risk categories (low, medium, high) and apply appropriate monitoring and due diligence measures accordingly.
• Enhanced Due Diligence (EDD): For any entity flagged as high-risk, we undertake additional verification and monitoring steps to thoroughly understand the nature of the risk and to implement suitable control measures.

5. Customer Identification and Verification (KYC)

• Third-Party KYC Through Transak: All KYC procedures are conducted through our partnership with Transak, ensuring a robust and compliant onboarding process for our users. We regularly review and audit these processes to ensure ongoing compliance with both U.S. and Saint Kitts and Nevis regulations.
• Verification Standards: We adhere to stringent verification standards, requiring documentary and non-documentary methods of identity verification, in alignment with the regulatory expectations of the jurisdictions we operate in.

6. Monitoring and Reporting

• Automated Transaction Monitoring: Our backend system, enhanced with AMLBot's capabilities, continuously monitors all transactions for signs of suspicious activities. Parameters include transaction size, frequency, geographical risks, and deviation from typical user behavior.
• Alerts and Investigations: Any transaction flagged by our system undergoes a thorough investigation by our compliance team. This includes reviewing transaction details, user history, and any relevant contextual information.
• Suspicious Activity Reporting (SAR): In cases where suspicious activity is confirmed, we file SARs with the appropriate regulatory bodies in the United States and Saint Kitts and Nevis, adhering to the mandated timelines and procedures.

7. Compliance and Oversight

• Dedicated Compliance Team: Our compliance team, led by a designated compliance officer, is responsible for the implementation, oversight, and enforcement of this AML policy. The team receives regular training to stay abreast of regulatory changes and emerging risks.
• Employee Training: All employees, especially those in customer-facing and transaction-monitoring roles, receive comprehensive training on AML principles, the specifics of our AML policy, and the procedures for detecting and reporting suspicious activities.

8. Record Keeping

• Transaction Records: We maintain detailed records of all transactions, including identity verification documents and records of all investigations and reports, for a minimum period of five years, as per regulatory requirements.
• Data Protection: In maintaining these records, we adhere to strict data protection standards, ensuring the confidentiality and security of all user information.

9. Auditing and Review

• Regular Audits: Our AML policy and practices are subject to regular internal audits to assess compliance and effectiveness. External audits are also conducted to provide an independent evaluation of our AML framework.
• Policy Updates: We regularly review and update our AML policy to reflect changes in regulatory requirements, operational practices, and emerging threats, ensuring our compliance framework remains robust and effective.

10. Reporting

• Compliance Reporting: We maintain open and cooperative relationships with regulatory authorities, ensuring timely and accurate reporting of suspicious activities and compliance with all reporting obligations.

11. Policy Review and Update

• Annual Review: This AML policy is reviewed at least annually to ensure it remains comprehensive, up-to-date, and in alignment with both current regulatory requirements and best practices.

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