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Anti-Money Laundering & Counter- Terrorist Financing Program

LAST UPDATED: DECEMBER 1, 2023

Preface

EEZE Inc. (“EEZE” or the “Company”) is a company that has multiple product offerings including the following: EEZE Brings Trust, Warranty, and Financing to Private Auto Sales by verifying People (protecting both parties from fraud) Vehicles (ensuring vehicle details & ownership), and Funds (real-time money transfers with security checks).

EEZE is committed to maintaining the highest standards in relation to managing compliance and risks associated with Anti-Money Laundering (“AML”), Combating the Financing of Terrorism (“CFT”) (collectively “AML Program”, unless otherwise noted). EEZE) is fully committed to maintaining an effective AML Program that incorporates sound business practices for a money service business and will examine its approach to AML on an ongoing basis.

The AML Policy is adopted by management. All employees, Board of Directors of or companies that provide outsourced services to EEZE must be knowledgeable about the company’s AML Program as it applies to their duties and responsibilities.

The AML Program shall ensure understanding, and, if deemed applicable, compliance with applicable rules and regulations, including, but not limited to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

What is Money Laundering?

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.

Generally, money laundering occurs in three stages:

  • Placement: Cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s cheques, or deposited into accounts at financial institutions.
  • Layering: Funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.
  • Integration: Funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Terrorist Financing

Terrorist Financing is the collection, possession, contribution, or solicitation of funds intended to be used to carry out or facilitate a terrorist activity or benefit a terrorist or terrorist group (including but not limited to persons designated by regulatory authorities as terrorists or terrorist groups). Terrorism is generally defined as the use of violence and intimidation in the pursuit of political aims.

Acts of terrorism usually involve violent acts that are dangerous to human life, intend to intimidate a civilian population or influence the policy or conduct of a government.

Terrorist financing, unlike money laundering as described above, is typically motivated by ideological, rather than profit-seeking concerns, and often may not involve the proceeds of criminal conduct.

Large sums are not necessarily involved, and the original funds may well be legitimate, rather than illegally obtained. The goal of terrorist financing is to establish flexible and mobile sources of funding for the purchase of products and services that will be used to further or commit terrorist acts.

A person may commit an offense of Terrorist Financing if they are involved in:

  • Fund raising – which covers inviting other people to provide money or other proceeds of crime;
  • Possession – which covers using money or other proceeds of crime.
  • Arrangement – which covers if a person knowingly enters into an arrangement whereby they provide funding for terrorists.

Other financial crime activities

Whilst the above acts of money laundering or terrorist financing are the primary offenses, there are several other offenses which are criminal offenses which may be linked to money laundering or terrorist activity, which include:

Human Trafficking and Smuggling
Kidnapping and Hostage Taking
Sexual Exploitation
Robbery and Theft
Illicit Trafficking in Narcotics and Psychotropic Substances
Smuggling
Illegal Arms Trafficking
Tax Crime relating to direct and/or indirect taxes
Trafficking in Stolen Goods
Extortion
Corruption
Forgery
Murder and Grievously Bodily Harm
Piracy
Fraud
Cybercrime
Counterfeiting Currency (including cash and virtual assets)
Terrorism
Counterfeiting and Piracy of Products or Services
Insider Trading and Market Manipulation
Environmental Crime
Participating in Organized Crime or Racketeering

EEZE is committed to adhering to complying with AML/CFT regulatory requirements that are deemed to be applicable to the Company as well as building and reinforcing a compliance-based culture.

Policy Principles

The objectives of the Anti-Money Laundering (“AML”) Program are to outline applicable legal and regulatory requirements and how EEZE will ensure compliance with its obligations, as deemed applicable.

EEZE requires its employees and any independent contractors, vendors, and consultants to follow federal and state/provincial laws and regulations.

AML/CTF Requirements

The AML Program includes the control framework for the following:

  • Customer identification and verification
  • AML and related training for appropriate staff

Senior Management of EEZE is responsible for reviewing and approving this Program Manual annually, at a minimum, or more frequently if circumstances require additional review.

Compliance Program Updates

The Company will update the AML program:

  • Annually each calendar year;
  • Where there are changes to the EEZE business model;
  • Where there are changes to applicable AML regulation or legislation;
  • Following internal reviews, as deemed necessary or applicable, to address any deficiencies identified by the Company.

All program updates will be logged and tracked by the Company. Records of program updates will be maintained for a minimum of five (5) years.

The Company will communicate relevant changes to staff members in a manner that ensures that all staff are aware of changes and able to perform their roles effectively.

Customer Identification and Verification Process

EEZE may work with third party vendors and/or service providers to ensure proper customer identification and verification.

To ascertain the identity of a client/customer, EEZE may use, collect, and or verify the following information, as deemed appropriate or legally permissive, either directly or through third party vendors or service providers, to verify the customer’s identity:

  • Name
  • Address (Address, Unit, State/Province, Postal Code, Country)

Not-for-Profit/Charity Organizations

To verify client/customer identity of a charitable organization, EEZE may obtain, either directly or through third party vendors or service providers, as deemed legally permissive, and confirm the accuracy of the following information:

  • Name of the Charity
  • The list of the Board of Directors/members
  • Location of Charity
  • Charity’s website URL

Adverse Media and Information

EEZE may use third party vendors or service providers to conduct adverse information checks on the Company’s behalf as part of the customer due diligence process and customer identification and verification refresh.
Relevant adverse media includes information obtained from reputable media sources relating to financial crimes, money laundering, drug trafficking, weapons trafficking, terrorist activity or financing, or sanctions.

Recordkeeping

EEZE will retain a full and accurate record of each client for at least five (5) years after the date of their onboarding with the Company.

Reporting Obligations

Staff Reporting Obligations

Staff must contact senior management with any suspicious activity. Senior Management may review the information and documents provided and decide as to any necessary action. The Company will maintain a summary with all supporting documentation as to the decision. Summaries and all supporting documentation and information must be maintained for a minimum of five (5) years from the date of decisioning.

Conducting or Supporting an Investigation

Internal Investigations

Internal investigations may be appropriate if the AML/CTF Program detects an unusual or abnormal event.

The internal investigative process includes all the following:

  • Identification of the target (customer, employee, officer, third party)
  • Purpose of the investigation
  • Scope of the investigation
  • Documentation of the internal investigative process and findings
  • Reporting to Competent Authorities, as appropriate or applicable.

The investigative process considerations include:

  • The tools and resources available
  • Other participating departments (ex: Legal, HR)
  • The volume of transactions needed for review.
  • The timeline of the investigation
  • Whether it is a potential money laundering or terrorist financing case
  • Geographical considerations
  • Data storage location
  • Data secrecy and protection requirements
  • How the investigation will impact ZumRails
  • Ethical issues
  • Fraud and scams

Investigations of Insiders

Inappropriate actions or behavior by Staff or others with insider information places EEZE at risk. Insider activity must be monitored.

In addition to the considerations listed in above in the Internal Investigations section, additional items to consider are:

  • Whether the investigation of the insider is appropriate
  • The role of senior management
  • Media relations
  • The process to respond to demands for information from Competent Authorities

External Investigations

Generally, senior management will handle, oversee, and respond to all external investigations by law enforcement, regulators, and government agencies.

Senior management, or their designated representative will handle all search warrant activity; however, if senior management or their designated representative is not available, Staff presented with a search warrant must take the following steps:

  • Notify senior management and their designated representative immediately by internally acceptable communication systems that have direct notifications.
  • Obtain a copy of the search warrant and forward to senior management and their designated representative.
  • If senior management or their designated representative is unavailable, remain present while all items or information is seized.
  • Obtain the inventory list from law enforcement.

YOU MUST NOT DO ANY OF THE FOLLOWING:

  • DO NOT prevent law enforcement from starting or conducting their search.
  • DO NOT notify the person or persons who are subject of the warrant that a warrant has been served and executed.
  • DO NOT arrange for law enforcement to visit other offices or data centers not listed on the warrant.
  • DO NOT allow law enforcement to orally extend the scope of the search beyond what is specifically listed in the search warrant.

Senior Management will determine whether any additional action is necessary as a result of the items outlined in the search warrant or property/information that is seized.

Ongoing Training Program

EEZE ensures that appropriate personnel are trained in applicable aspects of the Bank Secrecy Act (“BSA”) and other applicable laws and regulations, including, but not limited to, the Proceeds of Crime Money Laundering and Terrorist Financing Act (“PCMLTFA”).

EEZE senior management develops and maintains all AML training material and ensures that all Company employees receive AML training.
Senior management will maintain a training schedule that lists who is required to receive training, frequency of training along with the specific training that will be provided. EEZE requires that all relevant employees receive AML training at least every year. For any new employees or employees starting new positions, AML training shall be provided within 30 days of hire or within 30 days of starting their new position.

Training includes the overview of regulatory requirements and the company’s internal AML program, procedures, and processes. As part of ongoing training, the board of directors and senior management will be informed of changes and new developments in the regulatory requirements and applicable laws. While the board of directors may not require the same degree of training as company’s operations personnel, they need to understand the importance of AML/CFT regulatory requirements, the ramifications of noncompliance, and the risks posed to the company. The understanding of the PCMLTFA will enable the board of directors to adequately provide AML oversight; approve AML policies, procedures and processes; and provide sufficient resources in order to maintain an appropriate compliance regime.

Company training program will include:

  • Making sure that all employees know the responsibilities of the Company with compliance with
  • AML and CFT
  • Background on Anti-Money Laundering and Terrorist financing
  • Verifying client identification
  • How to recognize and report suspicious activity to senior management
  • Recordkeeping requirements
  • Explaining the penalties for not meeting requirements

Certification of AML Program Adoption

I, Derek Lloyd of EEZE Inc. hereby certify that this is the approved and current version of the Company’s Anti-Money Laundering (“AML”) Program which has been approved by senior management of the Company.

 

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