01. Purpose
The purpose of this policy is to prevent our services, platforms, commercial channels, and products from being used to facilitate money laundering, terrorist financing, or any other illicit activity, as well as to ensure comprehensive regulatory compliance in all our domestic and international commercial operations.
02. Scope
This policy applies to all employees, officers, contractors, agents, distributors, business partners, and any person or entity acting on behalf of HSO (hereinafter “Personnel and Collaborators”). It also extends to all business relationships with customers, suppliers, and technological allies involved in financial transactions with the Company.
03. Definitions
- Money Laundering: the process by which the nature, origin, location, disposition, or ownership of assets or funds derived from criminal activities is concealed or disguised, in order to make them appear legitimate.
- Terrorist Financing: the provision, collection, or making available of funds or economic resources, directly or indirectly, with the intention that they be used to commit terrorist acts or to support terrorist organizations.
- Red Flag: any fact, transaction, or conduct that deviates from the customer’s normal patterns or that, due to its nature, amount, frequency, geographic location, or concurrent circumstances, is suspicious of being linked to money laundering or terrorist financing.
04. AML Compliance Officer
HSO shall designate an AML Compliance Officer with the authority, independence, and resources necessary to oversee the implementation and effective compliance with this policy. Their responsibilities include:
- Developing, updating, and enforcing the AML policy and procedures.
- Designing and delivering periodic AML training programs to all Personnel and Collaborators.
- Monitoring transactions and business relationships for unusual or suspicious activities.
- Receiving, evaluating, and, where appropriate, reporting suspicious activities to FinCEN through the filing of the corresponding Suspicious Activity Reports (SARs), as well as to the relevant Florida or Mississippi state agencies.
- Conducting regular internal audits of the AML program.
- Retaining the documentation and records required by regulations for the established legal periods.
05. Customer Due Diligence (CDD)
Before establishing any business relationship involving financial transactions, HSO shall collect and verify the identity of all customers, partners, and suppliers. At a minimum, the following shall be collected: full name or legal name, physical address, date of incorporation or birth, tax identification number (EIN or SSN), and, where applicable, the ownership structure up to the ultimate beneficial owner. Each customer shall be classified into a risk level (low, medium, or high) based on factors such as country of domicile, industry sector, expected transactional pattern, and payment channels used. For high-risk customers, Enhanced Due Diligence (EDD) shall be applied, which includes obtaining additional documentation, identification of the ultimate beneficial owner, the source of funds, and senior management approval.
06. Ongoing Monitoring and Suspicious Activity Reporting
Transactions and account activity shall be continuously monitored to detect deviations from the assigned risk profile. All Personnel and Collaborators are obligated to immediately report to the AML Compliance Officer any suspicious operation or conduct of which they become aware. If, after evaluation, it is determined that there are reasonable grounds to suspect a connection to money laundering or terrorist financing, a SAR shall be filed with FinCEN within the legally established deadlines. It is strictly prohibited to inform the customer or third parties about the existence of a suspicious activity report (“No Tipping Off”).
07. Record Keeping
All documentation relating to customer identification, risk assessments, suspicion reports, and transaction records shall be retained for a minimum of five (5) years from the end of the business relationship, or for the longer period required by applicable regulations. Records shall be kept in a secure format and shall be accessible for review by regulatory authorities.
08. Training and Awareness
HSO shall provide AML training to all Personnel and Collaborators upon their incorporation and, subsequently, on an annual basis. The training shall cover legal obligations, identification of red flags, and internal reporting procedures. Periodic awareness campaigns shall be carried out and relevant regulatory updates shall be disseminated.
09. Sanctions and Watchlists
HSO shall not establish business relationships or conduct transactions with persons or entities included on the sanctions lists issued by the Office of Foreign Assets Control (OFAC), the United Nations, the European Union, or other competent sanctioning bodies. Before initiating any business relationship, all potential customers shall be screened against such lists, as well as against Politically Exposed Persons (PEP) lists and adverse media.
10. Consequences of Non-Compliance
Non-compliance with this policy by any employee, collaborator, or partner may result in disciplinary measures, including termination of the employment or contractual relationship, and notification to the competent authorities when the conduct could constitute a criminal or administrative offense. Violations of AML regulations can carry severe criminal and financial penalties for both the company and the individuals involved.
11. Policy Review and Update
This policy shall be reviewed at least annually, or immediately upon significant regulatory changes. Updates shall be communicated to all Personnel and Collaborators as soon as possible.
12. Contact
For any questions, communications, or reports related to this AML Policy, please contact the AML Compliance Officer through the following channels:
- Email: legal@huronsmithoil.com
- Phone: +1 (866) 954-5938
- Postal address: 204 Hays St, Batesville, Mississippi, 38606, USA