Company Name: Starsky Global Inc.
Jurisdiction: United States
Effective Date: August 2022
The purpose of this Anti-Money Laundering (AML) Policy is to ensure that Starsky Global Inc. complies with applicable U.S. laws and regulations including the Bank Secrecy Act (BSA) and guidance from the Financial Crimes Enforcement Network (FinCEN). The Company is committed to preventing the use of its services for money laundering, terrorist financing, or other illicit activity.
This policy applies to:
All users of Starsky Global’s products and services
All employees, contractors, and officers of Starsky Global Inc.
Starsky Global Inc. complies with:
The Bank Secrecy Act (BSA)
The USA PATRIOT Act
FinCEN guidance for virtual currency businesses
FATF Recommendations
Relevant state-level MSB regulations
A dedicated AML Compliance Officer is appointed to:
Implement and oversee AML controls
Monitor transactions and user behavior
File Suspicious Activity Reports (SARs)
Interface with regulatory bodies and law enforcement
Maintain audit trails and documentation
Starsky Global utilizes automated and manual monitoring systems to identify red flags such as:
Structuring (smurfing)
Rapid in-and-out fund movement
High-value transactions inconsistent with profile
Usage patterns matching known laundering techniques
The company files SARs with FinCEN in compliance with reporting thresholds and timelines. Reports are submitted confidentially and stored securely.
All AML-related records are retained for a minimum of five (5) years, including:
SARs
Monitoring logs
Internal investigation notes
All staff members undergo AML training:
During onboarding
Annually thereafter
Training covers red flag detection, legal obligations, and reporting procedures.
AML controls and practices are reviewed annually by an internal or external compliance auditor to ensure effectiveness and regulatory compliance.
This policy is reviewed at least annually or upon significant regulatory changes.
Authorized by:
Starsky Global Inc.
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